Countdown to Compliance: Ringing in 2025 with AML Readiness

For Registered Investment Advisers (RIAs) and Exempt Reporting Advisers (ERAs), the new year brings both opportunity and responsibility, and a chance to set the tone for success in an evolving AML compliance landscape.

With the countdown underway for FinCEN’s Anti-Money Laundering (AML) Rule, now is the time to act. Taking proactive steps today can help your firm avoid last-minute stress, meet upcoming requirements with confidence, and help ensure full AML compliance readiness.

Who should count down?

As the clock ticks toward the January 2026 deadline, it’s essential to determine whether your firm falls under the new FinCEN AML Rule. Here’s who needs to act:

Included:

• RIAs with over $110 million in assets under management (AUM)
• ERAs, regardless of AUM
• Foreign advisers serving U.S.-based clients or funds

Excluded:

• State-registered advisers, pension consultants, family offices, and certain foreign advisers with limited U.S. connections

If your firm engages with U.S. clients or investors, it’s time to evaluate your compliance obligations.

Your New Year’s checklist

As you set your firm’s resolutions, start with these key AML compliance actions:

1. Conduct a risk assessment: Identify and prioritize risks tied to your firm’s geography, clients, and services.
2. Update policies and procedures: Align internal processes with the rule’s requirements to ensure they are practical and enforceable.
3. Appoint an AML Compliance Officer (AMLCO): Designate a qualified individual to oversee and implement your AML program.
4. Engage trusted partners: Collaborate with custodians and third-party providers for seamless compliance.
5. Train your team: Provide targeted training to ensure employees understand their roles in meeting AML requirements.

Avoid dropping the ball

Outsourcing certain compliance functions can help streamline your program, but ultimate responsibility still rests with your firm. Avoid these missteps:

• Skipping due diligence on third-party providers
• Neglecting clear contractual agreements for outsourced services
• Failing to regularly review and verify third-party processes

Accountability starts and ends with your firm, so consistent oversight is non-negotiable.

The advantage of early preparation

The January 2026 deadline may feel distant, but the time to act is now. By getting ahead in 2025, your firm can avoid the stress of last-minute compliance efforts and strengthen trust with clients, investors, and regulators.

Preparation helps position your firm for success in a competitive market.

How we help

Our AML and Financial Crimes practice offers advisory services and solutions to help financial services firms meet regulatory obligations and address evolving risks. We work with investment advisers and broker-dealers, among others, to assess risk, develop policies and procedures, and perform independent tests and gap analyses.

To fully optimize efficiency and help your firm meet its data screening, ongoing monitoring, remediation, and reporting needs, we can help you incorporate:

• Outsourced managed services - Our full-service, single vendor offering provided and supported by our team of compliance professionals, which includes Certified Anti-Money Laundering Specialists (CAMS), and other industry leading financial crimes certificates.
• ComplianceAlpha^® regulatory technology - Our platform serves as a command center that automates data screening, enables continuous risk surveillance, maintains detailed records for regulatory reporting, and helps ensure compliance with global AML standards, including OFAC, FinCEN, the USA PATRIOT Act, MLD5, FINRA, SEC, and BSA.

Reach out to your ACA consultant or contact us to find out how ACA can help you meet your AML requirements.