Deadline reference

Investment adviser AML/CFT program and SAR rule: delayed effective date

91 FR 36 (final rule delaying the effective date of 89 FR 72156). FinCEN, United States (federal). Fixed date; binding rule.

Not legal advice. The period or date below is quoted from the official source with its conditions; whether and how it applies depends on your firm's facts and your actual regulatory correspondence. Confirm it in the official source.

Status: Active. Last checked 2026-11-09. All references.

Who it applies to

SEC-registered investment advisers, Exempt reporting advisers.

  • Investment advisers covered by the rule published September 4, 2024, at 89 FR 72156, as described in that rule.

    Sources: [1] DATES

Exclusions

No exclusions recorded.

The published period or date

Official text
As of December 31, 2025, the effective date of the rule published September 4, 2024, at 89 FR 72156 is delayed until January 1, 2028. This rule is effective January 1, 2028.
Type
Fixed date
Fixed date
2028-01-01
Legal status
Binding rule.
Effective
2028-01-01 to present
Conditions and transitions
In the final rule's background, FinCEN recounts that in its September 2025 proposal it assessed that delaying the effective date would give it an opportunity to review the rule and, as applicable, ensure it is effectively tailored. Confirm the current status before relying on this date. A FinCEN proposed rule on AML/CFT programs published in April 2026 states that it does not propose any amendments to the adviser rule and describes that rule as delayed until January 1, 2028. A proposal changes nothing until it is finalized. The underlying program and reporting obligations are set out in the 2024 rule and are not reproduced here.
Sources and locators
[1] DATES; Section II.B, Background (IA AML Effective Date NPRM); [2] Section I, Executive Summary, note on the investment adviser rule

No due date is computed here. The toolkit does not interpret event-relative periods, count business days or hold a holiday calendar.

Cite

Cite the official source first. Then: Taft Compliance Group, Exam-prep toolkit (draft), deadline reference dl-ria-aml-rule-effective-date, https://taftcompliance.com/resources/exam-prep-toolkit/deadlines/dl-ria-aml-rule-effective-date, last checked 2026-11-09.

Sources

  1. Office of the Federal Register (Financial Crimes Enforcement Network final rule), Delaying the Effective Date of the Anti-Money Laundering/Countering the Financing of Terrorism Program and Suspicious Activity Report Filing Requirements for Registered Investment Advisers and Exempt Reporting Advisers, 91 FR 36. official release. DATES section and Section II.B, Background (IA AML Effective Date NPRM).

    https://www.federalregister.gov/documents/2026/01/02/2025-24184/delaying-the-effective-date-of-the-anti-money-launderingcountering-the-financing-of-terrorism

    Checked 2026-11-09; published 2026-01-02; effective 2028-01-01.

    Supporting passage

    DATES: As of December 31, 2025, the effective date of the rule published September 4, 2024, at 89 FR 72156 is delayed until January 1, 2028. This rule is effective January 1, 2028. [...] In the IA AML Effective Date NPRM, FinCEN assessed that delaying the effective date of the IA AML Rule would pose a number of advantages, including providing FinCEN an opportunity to review the IA AML Rule and, as applicable, ensure the IA AML Rule is effectively tailored.

  2. Office of the Federal Register (Financial Crimes Enforcement Network proposed rule), Anti-Money Laundering and Countering the Financing of Terrorism Programs (proposed rule), 91 FR 18704. official release. Section I, Executive Summary, note on the investment adviser rule.

    https://www.federalregister.gov/documents/2026/04/10/2026-07033/anti-money-laundering-and-countering-the-financing-of-terrorism-programs

    Checked 2026-11-09; published 2026-04-10.

    Supporting passage

    FinCEN notes this proposed rule does not propose any amendments to the final rule establishing AML/CFT and suspicious activity report (SAR) filing requirements for registered investment advisers and exempt reporting advisers, which has been delayed until January 1, 2028.

Changes to this reference

No released changes.

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