Well, no. Not necessarily. And particularly not in relation to financial crime where politicians eat your lunch if a lobbyist is paying for it.

In the 1990s, US broker-dealers and "hedge funds" simply refused to provide KYC information to foreign stockbrokers, saying that information relating to their customers was commercial information and they would not provide it. In fact, the truth was that those businesses in the USA had no obligation, similar to that on their foreign equivalents, to have effective counter-money laundering measures including a know-your-customer process.

There were many efforts to bring such businesses within the scope of the USA's formal regulatory regime and eventually broker-dealers were. But "hedge funds" (which are not hedge funds at all, but are private investment advisory businesses that trade with their customers money) escaped the net.

When the USA PATRIOT Act was drafted, one of the bits of legislative flotsam and jetsum that had been unsuccessful was sewn into the Act. The necessary obligations were to be imposed and in effect before June 2002.

No. Not going to happen, the industry quietly said into its sleeves. And it hasn't.

Several attempts have been made to get to a final rule. This process is not subject to the same type of delay as legislative change: it doesn't get run out of time in the way a Bill does. It survices changes in administration because (however flawed this argument is) if it's in an Act, it's the will of the people.

The provision required by the Act did reach the stage of being "A Draft Final Rule" in 2008. But in November that year, FinCEN withdrew it saying it was not needed because "we have eyes on the money through the banks".

Now, seven years later, as efforts have persisted to make such a Rule, there's news from The U.S. Department of The Treasury."

In its breathless capital letters laden headline it says "Treasury Announces Postponement and Reopening of Investment Adviser Rule."

The only good thing about this is that it spells "adviser" correctly.

Here's the failed Final Rule, 2025 style: https://www.federalregister.gov/documents/2024/09/04/2024-19260/financi…

And here's Treasury's media release: https://home.treasury.gov/news/press-releases/sb0201

Honestly, it's unlikely that Treasury has had much of a hand in this latest mindfart. Treasury wants it done because there is a gaping hole in its FinCEN reporting, a hole that is exploited by anyone that feels like it to run Ponzi schemes, investment advice frauds, large scale money laundering and - even - corporate raids aimed at destablising companies, industries and economies. It is not an exaggeration to say that it can be used as a vehicle for corporate, political and national espionage.

But it was again left to FinCEN to make public excuses. This time it "In order to ensure efficient regulation that appropriately balances costs and benefits" and "to revisit the scope of the IA AML Rule at a future date. FinCEN anticipates delaying the effective date of the IA AML Rule from January 1, 2026, until January 1, 2028. "

As if....