The Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of the Treasury, has issued a final rule requiring certain investment advisers, including Registered Investment Advisers (RIAs) and Exempt Reporting Advisers (ERAs), to implement Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) programs and report suspicious activities through Suspicious Activity Reports (SARs). This rule designates investment advisers as “financial institutions” under the Bank Secrecy Act (BSA) and sets minimum standards for AML/CFT compliance to mitigate risks of money laundering, terrorism financing, and other illicit activities. The rule, effective January 1, 2026, aims to protect the U.S. financial system from misuse by illicit actors, including foreign states, and strengthens the overall regulatory framework governing investment advisers.
Read the unpublished version here: RIN: 1506-AB58