FinCEN's New AML Rule for Investment Advisers Triggers Day-One Scrutiny

A landmark anti-money laundering (AML) rule from FinCEN, which came into force on January 1, 2026, now designates nearly all SEC-registered investment advisers as 'financial institutions' under the Bank Secrecy Act. This mandates risk-based AML programs, Suspicious Activity Report (SAR) filings, and other BSA obligations, with examination and enforcement delegated to the SEC.