Does the January 1, 2028 AML deadline still apply?
As things stand today, yes, the rule is in force and the compliance date is January 1, 2028. That date has already moved once, and FinCEN has said it intends to look at the rule again, which is worth understanding honestly rather than glossing over.
The date, and its one move so far
The AML rule for investment advisers was finalized on September 4, 2024 (89 FR 72156), originally with a compliance date of January 1, 2026. FinCEN later delayed that date: "FinCEN, compliance-date delay, 91 FR 36, release 2025-24184 (published January 2, 2026): the compliance date moves from January 1, 2026 to January 1, 2028." The rule itself did not change in that delay, only the date by which covered firms have to be compliant with it.
A delay is not a withdrawal
It is worth being precise about what happened and what did not. FinCEN pushed the compliance date back by two years. It did not withdraw the final rule, did not reopen the rule's substantive requirements for a new comment period, and did not signal that covered firms are no longer expected to build a program. As of today, the rule stands and the date is January 1, 2028.
The honest caveat
FinCEN has also said, in its notice on the delay, that it intends to revisit the rule "consistent with the Administration's deregulatory agenda" (91 FR 36, January 2, 2026). That is a real signal that the requirement's substance, not just its date, could still change before 2028 arrives. Nothing about that statement has changed the rule as it stands today, and a firm that waits for a change which may not come risks having little runway left if it does not. Check where your firm currently stands, and revisit this page: it will be updated if the rule itself changes.
This page is independent research, not legal advice. It quotes FinCEN's own rulemaking with pinpoint citations. Verify anything load-bearing against the Federal Register text itself before acting on it.