Key players include FinCEN (U.S. Treasury's Financial Crimes Enforcement Network), the SEC (overseeing RIAs/ERAs), and covered advisers excluding mid-size advisers, multi-state advisers, pension consultants, family offices, sub-advised fund advisers, and those not reporting AUM. Advisers must implement policies to prevent money laundering and terrorist financing, with delegation allowed to third parties but ultimate responsibility retained.[1][2][3][4][6]
The rule stemmed from FATF-identified gaps in U.S. AML standards (noted in 2016), aiming for uniformity with banks/broker-dealers and addressing "shopping" for lax advisers; timeline: proposed earlier, finalized 2024, compliance set for 2026, paused late 2025 amid industry pushback. FinCEN cited a broader review to potentially reduce burdens and revisit customer identification proposals.[4][5][6][7][8][10]
Newsworthy now (January 2026) as the postponement, formalized post-January 1 deadline miss, grants two extra years for compliance amid unsettled requirements, easing immediate pressure on advisers preparing gap analyses and training. This shift impacts preparations for SAR filings and programs, with FinCEN soliciting comments on changes.[4][5][7]