Roadmap to AML/CFT Rule Compliance and Readiness

Custodians and broker-dealers have had to comply with AML requirements for years, but outside of a few specific scenarios, AML was a voluntary practice for advisers. But starting on January 1, 2026, advisers will now have to comply with formal requirements as part of FinCEN’s AML/CFT Rule, which includes six key requirements, including filing necessary Suspicious Activity Reports (SARs) and Currency Transaction Reports (CTRs).

This new rule has understandably raised questions among advisers who will be trying to navigate these new requirements for the first time. The AML/CFT Rule will require advisers to build a new program, conduct training, and have mechanisms in place to frequently review client transactions and related activities. Compliance will require planning and coordination with key stakeholders.

To help ensure advisers are prepared to meet these new requirements, we developed the roadmap below, including suggested timing and steps advisers should consider in preparing for the January 1, 2026, compliance deadline, as well as ongoing compliance.

Q3 2025:

• Develop your AML/CFT Program
  • Write Policies and Procedures
  • Name an AML/CFT officer
  • Train key personnel and leadership on AML
  • Obtain board approval
  • Create customer risk profiles

Q4 2025:

• Train employees on Suspicious Activity Reporting and individuals responsible for SAR filing
• Test 314(a) Request Screening Capabilities
• Review exposure to:
  • Travel Rules
  • Currency Transactions
  • Correspondence Accounts and Private Banking Accounts

After January 1, 2026:

• Arrange for an independent test of the AML/CFT Program for the calendar year 2026
• Ongoing Training
• Ongoing Customer Due Diligence
• Test implementation and recordkeeping

Questions?

Fairview’s AML/CFT team can help RIAs and ERAs meet this new requirement. To learn more, click here or contact us to speak with a member of our team.