IAA Requests Reconsideration of AML Rules | Maxwell Baker Insights
Vigilant Insights
Introduction
The Investment Advisor Association (IAA) has asked for the comment period to be reopened for rules approved last year by the SEC related to AML along with a proposed Rule related to Customer Identification Programs.
With the SEC under new leadership, and the Division under a structural overhaul, the industry is hoping for relief from many of the proposed and adopted Rules from the previous administration.
Vigilant Director, Maxwell Baker, Esq., provided his insights on FundFire discussing the effects of the new AML Rule on Firms.
Maxwell Baker Insights
With the AML regulation having a compliance deadline of January 1st, 2026, Maxwell opined that it is a heavy lift for RIAs in a short period to implement the changes that are required to maintain compliance.
Smaller Firms will have significant difficulties if they are not affiliated with a Broker-Dealer.
Maxwell warns that RIAs are required to create an entire AML program from the ground up, which would require them to dedicate significant resources.
Tasks include:
- Education on relevant Regulation
- Developing Policies; and
- Implementing Systems for monitoring.
Maxwell reminds RIAs that they will need to also assess the AML Policies of any Service Providers that are relevant to the RIAs obligations.
Vigilant’s Conclusion
Developing an AML program takes considerable experience and resources.
Vigilant provides cost effective Compliance Solutions, bringing hundreds of years of collective compliance experience to the table to help your Firm create efficient processes that hold up to regulatory scrutiny.
While there may be some hope for relief with the new SEC Leadership, Firms should continue to prepare for the compliance date as failing to have a program (if relief is not granted) would cause significant regulatory headaches.
Reach out to us today with any questions you may have.