Advisers should treat this as both regulatory relief and a signal that the contours of their future AML obligations remain unsettled. Because the AML rule is already a final rule, any future changes would need to be proposed as separate amendments, each subject to its own notice-and-comment process. Given its close connection to the AML rule, most observers expect FinCEN and the SEC to proceed on a coordinated basis, though no timeframe has yet been announced. The bottom line is that investment advisers have gained additional time before any AML obligations under this rule formally take effect, although the contours and applicability of those obligations remain in flux. Advisers therefore should be prepared for further changes to emerge in the design and scope of FinCEN’s investment adviser AML regime, as FinCEN reconsiders the rule.