The Financial Crimes Enforcement Network (FinCEN) first proposed requiring investment advisers to adopt anti-money laundering programs more than two decades ago. More recently, on February 15, 2024, FinCEN issued a notice of proposed rulemaking (NPRM), which would add certain investment advisers to the definition of “financial institution” subject to the Bank Secrecy Act (BSA); require those advisers to establish anti-money laundering/countering the financing of terrorism (collectively, AML) programs and report suspicious activity to FinCEN; and make other related changes to FinCEN regulations. On August 28, 2024, FinCEN adopted final AML rules (Rules) with some refinements to the NPRM. The Rules subject, with limited exceptions, all advisers registered or required to register with the SEC pursuant to Section 203 of the Investment Advisers Act of 1940 and all exempt reporting advisers to the AML regime under the BSA. This first article in a two-part series discusses the applicability of the Rules, their key provisions and how they differ from the NPRM. The second article will examine the key challenges fund managers will face in complying with the Rules and provide the steps they should take to do so. See our two-part series on the NPRM: “Parameters of the Rules and the Types of Managers Affected” (Apr. 18, 2024); and “Difficult Provisions, Potential SEC Examinations and Likelihood of Adoption” (May 2, 2024).