On September 22, 2025, the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of the Treasury (Treasury) hit pause on its aggressive advancement of anti-money laundering (AML) and countering the financing of terrorism efforts with the publication of a Notice of Proposed Rulemaking (NPRM), which seeks to push back the compliance date for the AML Rules (Rules) for investment advisers by two years, from January 1, 2026, to January 1, 2028. A comment period on the proposal closed on October 22, 2025. FinCEN’s rationale for the postponement is that the investment adviser sector has grown so dramatically, and the costs of the compliance programs envisioned under the Rules are so high, that more time is needed to reassess the Rules and consider changes to them. But the NPRM has fueled controversy, driving three lawmakers to send a letter (Letter) to Secretary of the Treasury Scott Bessent expressing alarm over a delay to the implementation of policies designed to protect investment advisers and the U.S. financial system. This article summarizes the NPRM and the Letter, explores the NPRM’s impact on the proposed customer identification program requirements and presents practical takeaways, with commentary from legal experts. See our two-part series on the Rules: “Parsing FinCEN’s Final AML Rules for Investment Advisers” (Nov. 7, 2024); and “Understanding the Implications for Hedge Fund Managers” (Nov. 21, 2024).