Treasury Announces Postponement and Reopening of Investment Adviser Rule

The Trump administration has announced a two-year delay in the implementation of the Investment Adviser Rule (IA AML Rule), which was slated to take effect in just a few months, on January 1, 2026. The new rule was designed and written to prevent criminals and terrorists from utilizing the U.S. financial system to facilitate their unlawful conduct. The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) is taking the position that it wants to more carefully balance the goals of the rule with the burden it would place on various players in the financial sector.

FinCEN’s full press release is here.

Our blog on the current version of the rule is here.

When this rule eventually does go into effect, it will be crucial for Investment Advisers to be prepared. While regulatory compliance is always important, that is particularly true here, where the stakes are so high. We will continue to monitor the situation and provide our insights.

If you are an investment adviser or a compliance professional who wants to learn more about how these rules are likely to work in practice, and how to stay on the right side of the law, please contact a regulatory defense attorney at The Galbraith Law Firm by emailing inquiry@galbraithlawfirm.com or calling 212.203.1249, for a free confidential consultation.