New AML/CFT Regulations for U.S. Investment Advisers: What You Need to Know

Starting January 1, 2026, investment advisers in the U.S. will have to comply with Financial Crimes Enforcement Network’s (FinCEN’s) new anti-money laundering (AML) and countering the financing of terrorism (CFT) regulation. This rule applies to both registered investment advisers (RIAs) and exempt reporting advisers (ERAs).

Designed to align RIAs and ERAs with broader financial industry standards, the new rule requires the establishment of risk-based AML/CFT programs, appointment of an AML compliance officer, and compliance with reporting requirements such as Suspicious Activity Reports (SARs) and Currency Transaction Reports (CTRs).

To ensure your firm is prepared for these changes, we’ve created a cheat sheet with essential knowledge to help you better understand your regulatory obligations and how to meet them.

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What’s changing for investment advisers?

For the first time, RIAs and ERAs will fall under the scope of the Bank Secrecy Act (BSA), meaning they will need to establish and implement risk-based AML/CFT programs. This rule aims to bring these entities in line with the broader financial sector, which has long adhered to similar standards.

Key requirements

Under the new rules, RIAs and ERAs will need to:

• Implement a risk-based and reasonably designed AML/CFT program
• Conduct independent testing of their AML/CFT programs
• Appoint an AML Compliance Officer (AMLCO) to oversee the program
• File CTRs and SARs reports
• Retain records in accordance with the BSA’s recordkeeping and travel rules

Learn more about the AML/CFT regulations

Join us on November 21, 2024, at 11:00am EST | 8:00am PST for a webinar providing expert insights on how the new FinCEN AML/CFT rule will impact your firm. Stay ahead of the curve - register today to ensure you’re fully prepared.

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.