The FinCEN rule is delayed. The need to understand AML risk is not.
DFP Partners brings more than 20 years of AML experience to help investment advisers evaluate AML risk, build custom AML programs, and stay current as FinCEN revisits the AML requirements for 2028 and beyond.
FinCEN’s final Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) rule for certain SEC-registered investment advisers and exempt reporting advisers has not been withdrawn. Its effective date has been postponed until January 1, 2028, while FinCEN reviews the Rule’s scope and substance.
The delay removes the immediate compliance deadline, not the underlying AML risks. Depending on a firm’s business model, clients, investors, products, counterparties and other risk factors; thoughtful AML controls may be a sound business and compliance practice before a rule requires them.
DFP Partners can assess your exposure, identify gaps, develop a program tailored to your business, and monitor FinCEN and related regulatory developments so you are ready when any new requirements take effect.
The final rule remains in place with an effective date of January 1, 2028, though FinCEN is reviewing the rule’s scope and substance.
The separate 2024 Customer Identification Program (CIP) proposal is on pause in its current form. FinCEN has said any future joint proposal with the SEC would replace it. The 2024 proposal created no current investment adviser CIP requirement.
FinCEN is also revisiting AML/CFT program standards, which could affect the framework ultimately applied to investment advisers.
We can review your business model, clients and investors, products and services, money movement activities, custodial arrangements, geographic exposure, and any other relevant factors to determine where AML risk may exist and what controls would be beneficial.
We can build AML programs based on the business you conduct. This may include written AML policies and procedures, risk assessment methodology, escalation protocols, suspicious activity review, recordkeeping, and information-sharing controls.
We can help determine AML oversight, identify appropriate personnel, and establish a practical governance structure without adding unnecessary compliance infrastructure.
A written program only works if the people responsible for it know what to do. We provide targeted implementation support and training suited to the firm’s business, risks, and responsibilities.
S.D. Daniels & Co., LLC (SDDco-LLC), a subsidiary of DFP Partners, provides independent AML testing for FINRA member broker-dealers, insurance companies, and other financial institutions. For investment advisers with voluntary AML programs, or if the proposed rules subject a firm to testing requirements, SDDco-LLC can tailor the testing and provide a written report with findings and recommendations.
We monitor FinCEN, SEC and related AML/CFT developments, assess the impact on your firm, and update your program or implementation plan as needed. This keeps you ready without rebuilding the program every time the regulatory direction changes.
The Rule’s postponement gives advisers time to prepare for whatever form the future rules may take. During this period, a firm can identify what AML risks it may have and decide which controls make sense.
For some advisers, a documented risk assessment and limited controls may be enough. Others may warrant a more developed framework because of their investors, products, cross-border activity, private funds, transaction patterns, or business relationships.
In whatever form the revised rules ultimately take effect, a firm that has already identified its risks, documented its decisions, and established workable processes will be positioned to adapt.
DFP Partners has been in
business for over 60 years
Have been with us
for 10 years
Average industry tenure
at partner level
Deep AML Expertise
DFP Partners combines registered investment adviser compliance experience with deep, practical AML expertise. Our consultants have conducted more than 1,000 independent AML tests and coordinated hundreds of regulatory examinations involving AML issues. We know how AML programs operate in practice, how regulators examine them, and how to scale them appropriately. All SDDco-LLC testing professionals are certified CAMS who can provide independent testing of your AML/CFT program that is tailored to the aspects of AML requirements most relevant to your firm.
Whether you want to assess your exposure, put a program in place, or prepare for the next FinCEN development, we can help.
