For more than 20 years, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has attempted to impose anti-money laundering (AML) rules on private fund managers by expanding the definition of “financial institution” under the Bank Secrecy Act of 1970 to include certain investment advisers. As far back as 2002, FinCEN has proposed – and then withdrawn – rules that would have required designated investment advisers to, among other things, implement AML programs and file suspicious activity reports. FinCEN was finally successful in August 2024, when it adopted final AML rules (Rules) that, with limited exceptions, apply to all advisers registered or required to register with the SEC under Section 203 of the Investment Advisers Act of 1940, as well as all exempt reporting advisers. This second article in a two-part series examines the key challenges fund managers will face in complying with the Rules and provides the steps they should take. The first article discussed the applicability of the Rules, their key provisions and how they differ from the original proposal. See our two-part series on the 2015 FinCEN AML rule proposal: “How FinCEN’s Proposed AML Rule Will Affect Fund Managers and Other Investment Advisers” (Jun. 30, 2016); and “Steps Fund Managers and Other Investment Advisers Should Take Now to Prepare for FinCEN’s Proposed AML Rule” (Jul. 7, 2016).