RIAs face day-one AML scrutiny under new FinCEN rule - FinTech Global
FinCEN's new rule requires Registered Investment Advisers (RIAs) to implement AML programs and file Suspicious Activity Reports (SARs) from day one, extending BSA/AML obligations to a previously exempt sector.
Aforeworn detected this change in the Money Services & Money Transmitters space on July 6, 2026 and published this briefing so affected operators are forewarned rather than caught off guard. It is rated High urgency. RIAs, including those operating as money transmitters or handling virtual currency, and their compliance teams. should confirm how it applies to their specific situation before acting. There is a time constraint attached: The rule is effective 30 days after publication in the Federal Register; RIAs must comply by that date.. Acting after that point can mean penalties, a lapsed licence, or lost eligibility — exactly the kind of surprise Aforeworn exists to prevent. Aforeworn monitors Money Services & Money Transmitters continuously and turns every detected change into a plain-English briefing like this one, so you always know first. Forewarned is forearmed.
What changed
RIAs are now subject to AML program requirements, SAR filing, and recordkeeping under the Bank Secrecy Act, effective immediately upon the rule's effective date.
Who it affects
RIAs, including those operating as money transmitters or handling virtual currency, and their compliance teams.
What you must do
Adopt a written AML program, appoint a compliance officer, conduct independent testing, train staff, and file SARs as required.
Deadline
The rule is effective 30 days after publication in the Federal Register; RIAs must comply by that date.
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