Your Roadmap to Prepare for FinCEN’s AML Rule

With FinCEN’s Anti-Money Laundering (AML) Rule set to take effect in 2026, U.S. investment advisers face increased scrutiny to prevent financial crimes and align with global anti-money laundering (AML) standards. This rule expands the Bank Secrecy Act (BSA) requirements to include Registered Investment Advisers (RIAs) and Exempt Reporting Advisers (ERAs), making a strong AML compliance program essential.

To help your firm stay on track, we’ve developed a high-level timeline outlining key milestones to ensure compliance well before the deadline.

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Conduct a gap analysis (2 - 4 months)

The first step in preparing for the AML Rule is identifying where your firm stands and addressing existing weaknesses.

• Educate your team: Equip staff with knowledge about the rule’s requirements and their roles in compliance. Training sessions should focus on actionable insights and real-world applications.
• Analyze your current program: Review policies, systems, and workflows to identify gaps. Are your AML policies up to date? Do your systems support efficient reporting and risk assessment?
• Prioritize fixes: Categorize deficiencies by urgency and complexity to ensure critical areas are addressed first.

Collaborate on changes (6 - 12 months)

Once gaps are identified, it’s time to address them with intentional updates and alignment across your organization and partners.

• Update policies and procedures: Revise policies to meet the AML Rule’s requirements, tailoring them to your firm’s specific operations. Avoid generic solutions that don’t reflect your risk profile.
• Appoint an AML compliance officer (AMLCO): Designate a responsible individual or team to oversee compliance efforts. Their accountability is key to ensuring follow-through.
• Engage partners: Collaborate with third-party intermediaries, vendors, and service providers to align their workflows with your compliance updates. Strengthen oversight to address potential vulnerabilities.

Implementation and monitoring (2 months and beyond)

The final step is turning plans into action and embedding compliance into daily operations.

• Roll out changes: Implement updated policies and procedures across all levels of your organization.
• Integrate technology: Use regulatory technology to streamline reporting, monitoring, and risk assessment. Technology can enhance efficiency and reduce the risk of human error.
• Ongoing training: Provide regular, role-specific training to ensure employees stay informed about their responsibilities and the evolving regulatory landscape.
• Monitor and adjust: Continuously review your program to identify areas for improvement. Compliance is an ongoing effort, not a one-time task.

FinCEN’s AML Rule is not just another regulatory update. It closes loopholes in the financial system, strengthens defenses against illicit activity, and aligns the U.S. with global AML/CFT standards. Investment advisers play a critical role in this effort, and robust compliance programs are essential for safeguarding financial integrity.

How we help

Our AML and Financial Crimes practice supports investment advisers and broker-dealers in meeting regulatory obligations and managing risk. We offer:

• AML risk assessments and policy development: Risk assessment of the adviser’s compliance with relevant AML and sanctions regulations.
• AML program reviews: An independent review of the adviser’s AML program, aligning with FinCEN and SEC AML rules and industry best practices.
• Outsourced managed services: A full-service, single-vendor solution supported by our team of compliance professionals, including Certified Anti-Money Laundering Specialists (CAMS) and other industry-leading financial crimes experts.
• 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.

Whether launching, growing, or safeguarding your business, we provide end-to-end compliance support. Contact us today to get started.

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