New FinCEN Rule Expands AML/CFT Responsibilities for Investment Advisers: What Investment Advisers Need to Know

As of January 1, 2026, most investment advisers registered with the Securities and Exchange Commission (SEC) and SEC exempt reporting advisers (ERAs) will face new regulatory obligations under the Financial Crimes Enforcement Network’s (FinCEN) final rule on anti-money laundering (AML) and countering the financing of terrorism (CFT). This landmark rule brings many investment advisers under the Bank Secrecy Act’s (BSA) definition of “financial institution,” imposing direct requirements for establishing AML/CFT programs, conducting customer due diligence, and filing suspicious activity reports (SARs) for potentially illicit transactions.