On August 28, 2024, the Financial Crimes Enforcement Network (FinCEN) adopted final anti-money laundering (AML) rules for investment advisers, which were set to take effect on January 1, 2026. However, on August 5, 2025, FinCEN issued an order delaying that effective date until January 1, 2028, indicating its intention to revisit the scope of the rules at a later date. Nonetheless, a pair of SEC settlements serve as a reminder that although advisers are not yet required to have AML programs, those that do must ensure their AML processes align with their representations to investors regarding such programs. For example, the SEC fined an investment adviser that represented that it would confirm its investors’ identities and sources of funds but then failed to do so with respect to certain investors. Similarly, firms required to have AML programs must ensure they implement them effectively. In that regard, the SEC fined a broker-dealer that allegedly failed to follow its AML policies and procedures and maintain records regarding its customer due diligence activities. This article discusses both settlements, with commentary from Madelyn Calabrese, partner at Haynes and Boone. See our two-part series on FinCEN’s final AML rules: “Parsing FinCEN’s Final AML Rules” (Nov. 7, 2024); and “Understanding the Implications for Hedge Fund Managers” (Nov. 21, 2024).