FinCEN AML Rule 2026 | Réglementation & Conformité

Risk Landscape

The investment advisory sector has been vulnerable to some pretty sneaky characters. From foreign corruption to sophisticated fraud schemes, illicit actors have been eyeing the industry as their golden ticket into the U.S. financial system.

Treasury review identified more than 20 private fund advisers with significant ties to Russian oligarch investors or Russian-linked illicit activities, with the majority advising venture capital funds. (Source)

The investment advisory sector has been vulnerable to some pretty sneaky characters. From foreign corruption to sophisticated fraud schemes, illicit actors have been eyeing the industry as their golden ticket into the U.S. financial system.

Treasury review identified more than 20 private fund advisers with significant ties to Russian oligarch investors or Russian-linked illicit activities, with the majority advising venture capital funds. (Source)

The investment advisory sector has been vulnerable to some pretty sneaky characters. From foreign corruption to sophisticated fraud schemes, illicit actors have been eyeing the industry as their golden ticket into the U.S. financial system.

Treasury review identified more than 20 private fund advisers with significant ties to Russian oligarch investors or Russian-linked illicit activities, with the majority advising venture capital funds. (Source)

The investment advisory sector has been vulnerable to some pretty sneaky characters. From foreign corruption to sophisticated fraud schemes, illicit actors have been eyeing the industry as their golden ticket into the U.S. financial system.

Treasury review identified more than 20 private fund advisers with significant ties to Russian oligarch investors or Russian-linked illicit activities, with the majority advising venture capital funds. (Source)

Current Challenges in the system

Foreign Proceeds and Market Entry

Investment advisers often unknowingly serve as entry points for illicit foreign proceeds into the U.S. financial system.
These proceeds typically originate from foreign corruption, sophisticated fraud schemes, and tax evasion
Investment advisers' unique position makes them particularly vulnerable to exploitation, as they are often the initial point of contact for foreign capital entering U.S. markets

Structural Challenges

Multiple layers of legal entities complicate due diligence
Offshore structures obscure beneficial ownership
Varying regulatory standards across jurisdictions create gaps in oversight

Information Sharing Limitations

Investment advisers are currently prevented from participating in key information sharing programs, limiting access to critical data on suspected illicit finance activity.

Foreign Proceeds and Market Entry

Investment advisers often unknowingly serve as entry points for illicit foreign proceeds into the U.S. financial system.
These proceeds typically originate from foreign corruption, sophisticated fraud schemes, and tax evasion
Investment advisers' unique position makes them particularly vulnerable to exploitation, as they are often the initial point of contact for foreign capital entering U.S. markets

Structural Challenges

Multiple layers of legal entities complicate due diligence
Offshore structures obscure beneficial ownership
Varying regulatory standards across jurisdictions create gaps in oversight

Information Sharing Limitations

Investment advisers are currently prevented from participating in key information sharing programs, limiting access to critical data on suspected illicit finance activity.

Foreign Proceeds and Market Entry

Investment advisers often unknowingly serve as entry points for illicit foreign proceeds into the U.S. financial system.
These proceeds typically originate from foreign corruption, sophisticated fraud schemes, and tax evasion
Investment advisers' unique position makes them particularly vulnerable to exploitation, as they are often the initial point of contact for foreign capital entering U.S. markets

Structural Challenges

Multiple layers of legal entities complicate due diligence
Offshore structures obscure beneficial ownership
Varying regulatory standards across jurisdictions create gaps in oversight

Information Sharing Limitations

Investment advisers are currently prevented from participating in key information sharing programs, limiting access to critical data on suspected illicit finance activity.

June 2025 Update : Focus on Iran-Linked Illicit Finance

In light of FinCEN’s June 2025 Advisory (FIN-2025-A002), investment advisers should be aware of evolving risks tied to Iran’s illicit financial activities. Iran relies on a "shadow fleet" of aging, poorly documented oil tankers and a global "shadow banking" network of front companies and exchangers operating through the UAE, Hong Kong, and China.

These networks launder revenues from Iranian oil exports—often mislabeled as “Malaysian blend”—and route the proceeds to sanctioned terrorist groups such as the IRGC, Hizballah, the Houthis, and Hamas.

FinCEN recommends advisers incorporate these risks into their AML programs when reviewing:

International wire transfers to/from high-risk jurisdictions
Clients or counterparties with opaque ownership structures
Trade documentation anomalies (shipping routes, falsified cargo origin)

SAR Reporting: Flag suspicious activity tied to Iran with the keyword “IRAN-2025-A002” in the SAR report.

In light of FinCEN’s June 2025 Advisory (FIN-2025-A002), investment advisers should be aware of evolving risks tied to Iran’s illicit financial activities. Iran relies on a "shadow fleet" of aging, poorly documented oil tankers and a global "shadow banking" network of front companies and exchangers operating through the UAE, Hong Kong, and China.

These networks launder revenues from Iranian oil exports—often mislabeled as “Malaysian blend”—and route the proceeds to sanctioned terrorist groups such as the IRGC, Hizballah, the Houthis, and Hamas.

FinCEN recommends advisers incorporate these risks into their AML programs when reviewing:

International wire transfers to/from high-risk jurisdictions
Clients or counterparties with opaque ownership structures
Trade documentation anomalies (shipping routes, falsified cargo origin)

SAR Reporting: Flag suspicious activity tied to Iran with the keyword “IRAN-2025-A002” in the SAR report.

In light of FinCEN’s June 2025 Advisory (FIN-2025-A002), investment advisers should be aware of evolving risks tied to Iran’s illicit financial activities. Iran relies on a "shadow fleet" of aging, poorly documented oil tankers and a global "shadow banking" network of front companies and exchangers operating through the UAE, Hong Kong, and China.

These networks launder revenues from Iranian oil exports—often mislabeled as “Malaysian blend”—and route the proceeds to sanctioned terrorist groups such as the IRGC, Hizballah, the Houthis, and Hamas.

FinCEN recommends advisers incorporate these risks into their AML programs when reviewing:

International wire transfers to/from high-risk jurisdictions
Clients or counterparties with opaque ownership structures
Trade documentation anomalies (shipping routes, falsified cargo origin)

SAR Reporting: Flag suspicious activity tied to Iran with the keyword “IRAN-2025-A002” in the SAR report.

Foreign Proceeds and Market Entry

Investment advisers often unknowingly serve as entry points for illicit foreign proceeds into the U.S. financial system.
These proceeds typically originate from foreign corruption, sophisticated fraud schemes, and tax evasion
Investment advisers' unique position makes them particularly vulnerable to exploitation, as they are often the initial point of contact for foreign capital entering U.S. markets

Structural Challenges

Multiple layers of legal entities complicate due diligence
Offshore structures obscure beneficial ownership
Varying regulatory standards across jurisdictions create gaps in oversight

Information Sharing Limitations

Investment advisers are currently prevented from participating in key information sharing programs, limiting access to critical data on suspected illicit finance activity.

In light of FinCEN’s June 2025 Advisory (FIN-2025-A002), investment advisers should be aware of evolving risks tied to Iran’s illicit financial activities. Iran relies on a "shadow fleet" of aging, poorly documented oil tankers and a global "shadow banking" network of front companies and exchangers operating through the UAE, Hong Kong, and China.

These networks launder revenues from Iranian oil exports—often mislabeled as “Malaysian blend”—and route the proceeds to sanctioned terrorist groups such as the IRGC, Hizballah, the Houthis, and Hamas.

FinCEN recommends advisers incorporate these risks into their AML programs when reviewing:

International wire transfers to/from high-risk jurisdictions
Clients or counterparties with opaque ownership structures
Trade documentation anomalies (shipping routes, falsified cargo origin)

SAR Reporting: Flag suspicious activity tied to Iran with the keyword “IRAN-2025-A002” in the SAR report.

In light of FinCEN’s June 2025 Advisory (FIN-2025-A002), investment advisers should be aware of evolving risks tied to Iran’s illicit financial activities. Iran relies on a "shadow fleet" of aging, poorly documented oil tankers and a global "shadow banking" network of front companies and exchangers operating through the UAE, Hong Kong, and China.

These networks launder revenues from Iranian oil exports—often mislabeled as “Malaysian blend”—and route the proceeds to sanctioned terrorist groups such as the IRGC, Hizballah, the Houthis, and Hamas.

FinCEN recommends advisers incorporate these risks into their AML programs when reviewing:

International wire transfers to/from high-risk jurisdictions
Clients or counterparties with opaque ownership structures
Trade documentation anomalies (shipping routes, falsified cargo origin)

SAR Reporting: Flag suspicious activity tied to Iran with the keyword “IRAN-2025-A002” in the SAR report.

Core requirements

Scope of Application

Applies to:

SEC-registered investment advisers (RIAs)
Exempt Reporting Advisers (ERAs)

Notable Exclusions:

RIAs registered solely as mid-sized advisers, multi-state advisers, or pension consultants
RIAs with no assets under management (AUM)
State-registered advisers
Foreign private advisers and family offices

Foreign Advisers: Rule applies to U.S.-based activities and U.S. investors only.

Scope of Application

Applies to:

SEC-registered investment advisers (RIAs)
Exempt Reporting Advisers (ERAs)

Notable Exclusions:

RIAs registered solely as mid-sized advisers, multi-state advisers, or pension consultants
RIAs with no assets under management (AUM)
State-registered advisers
Foreign private advisers and family offices

Foreign Advisers: Rule applies to U.S.-based activities and U.S. investors only.

Scope of Application

Applies to:

SEC-registered investment advisers (RIAs)
Exempt Reporting Advisers (ERAs)

Notable Exclusions:

RIAs registered solely as mid-sized advisers, multi-state advisers, or pension consultants
RIAs with no assets under management (AUM)
State-registered advisers
Foreign private advisers and family offices

Foreign Advisers: Rule applies to U.S.-based activities and U.S. investors only.

Scope of Application

Applies to:

SEC-registered investment advisers (RIAs)
Exempt Reporting Advisers (ERAs)

Notable Exclusions:

RIAs registered solely as mid-sized advisers, multi-state advisers, or pension consultants
RIAs with no assets under management (AUM)
State-registered advisers
Foreign private advisers and family offices

Foreign Advisers: Rule applies to U.S.-based activities and U.S. investors only.

Key Changes:

Getting Compliant by 2026

To comply in time, advisers should begin preparing now:

Assess current compliance frameworks: Run a gap analysis based on FinCEN’s 5 core pillars
Update your risk model: Integrate typologies related to Iran, Russia, and offshore structures
Invest in compliance tech: Automate due diligence, SAR reporting, and document tracking
Train teams continuously: Include geopolitics, sanctions evasion, and transaction monitoring

To comply in time, advisers should begin preparing now:

Assess current compliance frameworks: Run a gap analysis based on FinCEN’s 5 core pillars
Update your risk model: Integrate typologies related to Iran, Russia, and offshore structures
Invest in compliance tech: Automate due diligence, SAR reporting, and document tracking
Train teams continuously: Include geopolitics, sanctions evasion, and transaction monitoring

To comply in time, advisers should begin preparing now:

Assess current compliance frameworks: Run a gap analysis based on FinCEN’s 5 core pillars
Update your risk model: Integrate typologies related to Iran, Russia, and offshore structures
Invest in compliance tech: Automate due diligence, SAR reporting, and document tracking
Train teams continuously: Include geopolitics, sanctions evasion, and transaction monitoring

To comply in time, advisers should begin preparing now:

Assess current compliance frameworks: Run a gap analysis based on FinCEN’s 5 core pillars
Update your risk model: Integrate typologies related to Iran, Russia, and offshore structures
Invest in compliance tech: Automate due diligence, SAR reporting, and document tracking
Train teams continuously: Include geopolitics, sanctions evasion, and transaction monitoring

How B4Finance Supports AML/CTF Readiness

B4finance turn-key platform is natively built to support a robust AML/CFT program, allowing fund managers to configure their due diligence rules, AML risk matrix, and perform ongoing monitoring of LPs records.

Benefits

Multi-jurisdictional AML risk scoring: You can build your own AML scoring matrix or rely on the standard one already configured in the platform and compliant with FinCen rule
Improved customer experience: Collect sensitive KYC data and documents from clients in a simple and effortless manner with smart forms
Increased process efficiency: Automate the verification process by using AI to effectively spot document alteration and spoofing attempts
Perpetual KYC: Continuous screening and updating of customer information are performed daily against PEP and sanctions lists
Regulatory reporting: Capabilities to export data in any format, easy to share with internal teams or Market Authority

B4finance turn-key platform is natively built to support a robust AML/CFT program, allowing fund managers to configure their due diligence rules, AML risk matrix, and perform ongoing monitoring of LPs records.

Benefits

Multi-jurisdictional AML risk scoring: You can build your own AML scoring matrix or rely on the standard one already configured in the platform and compliant with FinCen rule
Improved customer experience: Collect sensitive KYC data and documents from clients in a simple and effortless manner with smart forms
Increased process efficiency: Automate the verification process by using AI to effectively spot document alteration and spoofing attempts
Perpetual KYC: Continuous screening and updating of customer information are performed daily against PEP and sanctions lists
Regulatory reporting: Capabilities to export data in any format, easy to share with internal teams or Market Authority

B4finance turn-key platform is natively built to support a robust AML/CFT program, allowing fund managers to configure their due diligence rules, AML risk matrix, and perform ongoing monitoring of LPs records.

Benefits

Multi-jurisdictional AML risk scoring: You can build your own AML scoring matrix or rely on the standard one already configured in the platform and compliant with FinCen rule
Improved customer experience: Collect sensitive KYC data and documents from clients in a simple and effortless manner with smart forms
Increased process efficiency: Automate the verification process by using AI to effectively spot document alteration and spoofing attempts
Perpetual KYC: Continuous screening and updating of customer information are performed daily against PEP and sanctions lists
Regulatory reporting: Capabilities to export data in any format, easy to share with internal teams or Market Authority

B4finance turn-key platform is natively built to support a robust AML/CFT program, allowing fund managers to configure their due diligence rules, AML risk matrix, and perform ongoing monitoring of LPs records.

Benefits

Multi-jurisdictional AML risk scoring: You can build your own AML scoring matrix or rely on the standard one already configured in the platform and compliant with FinCen rule
Improved customer experience: Collect sensitive KYC data and documents from clients in a simple and effortless manner with smart forms
Increased process efficiency: Automate the verification process by using AI to effectively spot document alteration and spoofing attempts
Perpetual KYC: Continuous screening and updating of customer information are performed daily against PEP and sanctions lists
Regulatory reporting: Capabilities to export data in any format, easy to share with internal teams or Market Authority

Conclusion

This update, reflecting FinCEN’s latest geopolitical advisories, highlights the importance of continuously adapting AML programs in response to global threats. Iranian illicit finance channels represent a particularly urgent risk vector for investment advisers handling cross-border flows.

FinCEN’s AML rule introduces a new regulatory reality for investment advisers. While it imposes new responsibilities, it also presents an opportunity to reinforce risk management practices and embrace compliance innovation. Taking proactive steps today will position your firm to thrive—and stay protected—in this increasingly complex environment.

Disclaimer: This guide is for informational purposes and does not constitute legal advice.