United States
FinCEN Postpones Effective Date of Anti-Money-Laundering Rule for Investment Advisers and Exempt Reporting Advisers
On July 21, 2025, FinCEN announced it will delay the effective date of the final AML rule for certain investment advisers and exempt reporting advisers (IA AML Rule) from January 1, 2026, to January 1, 2028. The agency plans to reopen the rulemaking process to reconsider both the substance and scope of the rule, including jointly revisiting with the SEC the proposed Customer Identification Program (CIP) rule. This delay aims to better tailor regulatory requirements to the diverse business models and risk profiles in the investment adviser sector while providing regulatory certainty and reducing compliance burden uncertainty.
Takeaways:
– Stakeholders are encouraged to engage in public comment opportunities to influence rule design.
– Firms should proactively review and prepare their compliance programs anticipating future changes.
Sources:
https://home.treasury.gov/news/press-releases/sb0201
United Kingdom
FCA & Metropolitan Police Seize Seven Crypto ATMs
A joint operation between the FCA and the Metropolitan Police resulted in the seizure of seven unauthorized crypto ATMs and the arrest of two individuals on suspicion of running an illegal cryptoasset exchange and money laundering. Authorities searched four premises across southwest London. Both suspects were interviewed under caution and released pending further investigation.
Takeaways:
– No crypto ATMs are legally operated in the UK currently. Registration with the FCA is mandatory.
– Heightened monitoring and vigilance regarding cryptoasset-related onboarding, source of funds, and transaction flows are strongly advised.
International Standards
Wolfsberg Group Reaffirms Commitment to Risk-Based Approach in Financial Crime Compliance
The Wolfsberg Group released an updated statement (July 2025) emphasizing three pillars of a modern risk-based approach (RBA) for financial institutions’ financial crime risk management:
– Proportionality: Tailor AML/CTF programs to institutional size, business model, and customer risk profiles-not one-size-fits-all.
– Prioritisation: Direct attention and resources to higher-risk customers, activities, and areas.
– Effectiveness: Focus on outcomes over rigid technical compliance; adapt dynamically as risks evolve.
Takeaways:
– Allocation of compliance resources should focus on riskier areas, not just broad rules.
– Engagement with evolving RBA frameworks is essential for both effective compliance and positive regulatory outcomes.