Is my firm covered by FinCEN’s AML rule?
The three lines on Form ADV that decide it, and why FinCEN refused to exempt small firms by headcount.
Read the pageIs your advisory firm actually in scope for FinCEN’s AML rule?
11,351 SEC-registered advisory firms already fall inside FinCEN’s AML scope. Enter your CRD number and we read your firm’s own public Form ADV filing to show exactly which parts of the rule apply, plus the one thing most advisers wrongly assume their custodian already handles.
Quick answer
- FinCEN’s AML rule for investment advisers turns on three lines of your own Form ADV: SEC registration, no broker-dealer affiliation covering you, and your firm’s own risk factors.
- Enter your CRD number and the check reads your firm’s public Form ADV filing, no account, about a minute.
- FinCEN was asked to let advisers rely on their custodian’s AML program instead, and said no: the compliance deadline is January 1, 2028.
- Your Form ADV declares you a “large advisory firm”
- You report no broker-dealer among related persons, and no employee who is one
- You advise at least one private fund
- Your firm has custody of client cash or securities
- A related person has custody of client assets
11,351 SEC-registered firms indexed, from the SEC roster dated 2026-10-02. No account, nothing stored. Method and sources.
- Total AUM inside FinCEN’s AML scope
- $34.15 trillion
- Median staff, across every firm in scope
- 7
- Firms with fewer than 20 people
- 9,225 (81.3%)
- Firms with custody of client cash or securities
- 6,387 (56.3%)
This is not a guess. It is three lines on a form you already filed.
FinCEN’s investment adviser AML rule does not apply based on how big or small you feel, or what a compliance newsletter told you last quarter. It applies based on three specific answers on your own Form ADV, the same public filing the SEC already has on record for your firm.
SEC-registered, not state-registered
Item 2A(1) of Form ADV. “Large advisory firm” status is what puts a firm under the SEC rather than a state regulator, and that is the line the rule’s scope test runs on.
No broker-dealer to lean on
Items 7A(1) and 5B(2). No broker-dealer among related persons, and no employee who is a registered rep of one, so there is no affiliated firm’s AML program already covering you.
Your own risk factors
Private funds, custody, wrap fee programs, foreign regulators, paid solicitors: whichever of these your firm discloses shapes what your specific AML program needs to cover.
The RIA AML Readiness Index
582 advisory firms report a staff of one person or fewer. Every one of them has to write an AML program, name a compliance officer, and pass an independent annual test, the same rule that applies to a 200-person firm.
These 11,351 firms are every investment adviser whose own Form ADV clears FinCEN’s three-part AML scope test: SEC-registered rather than state-registered, no broker-dealer among related persons, no employee registered with one. See the exact filter and sources. The source is the SEC’s own public roster of investment advisers, dated 2026-10-02, self-reported by each firm and republished by the SEC on its own monthly schedule, so a firm that has since grown, shrunk, or amended its filing will not show here as it stands today.
- Total AUM inside FinCEN’s AML scope
- $34.15 trillion
- Median staff, across every firm in scope
- 7
- Firms with fewer than 20 people
- 9,225 (81.3%)
- Firms with 5 people or fewer
- 4,691 (41.3%)
- Firms with a staff of one person or fewer
- 582 (5.1%)
- Firms with custody of client cash or securities
- 6,387 (56.3%)
- Firms where a related person holds custody
- 3,898 (34.3%)
- Firms advising at least one private fund
- 4,528 (39.9%)
- 5-or-fewer-person firms that also hold custody
- 2,061 (18.2%)
- 5-or-fewer-person firms that also advise a private fund
- 1,023 (9.0%)
- Median AUM, across every firm in scope
- $431.1 million
- Median AUM among 5-or-fewer-person firms
- $215.8 million
Ten largest states in this population. See how firms actually build the program required here on the comparison page.
Check whether your own firm is on this listRead the primary sources first
Does my custodian already handle this?
The most common assumption an adviser makes, and FinCEN’s own written refusal to let you rely on it.
Read the pageHow much does an AML program cost?
FinCEN’s own estimate for the one-time build, and the recurring annual cost almost nobody quotes.
Read the pageWhat is the annual independent test?
What it has to cover, who is allowed to perform it, and how often.
Read the pageDoes the 2028 deadline still stand?
The one delay so far, why a delay is not a withdrawal, and the deregulatory review FinCEN itself announced.
Read the pageHow the check works
Enter your CRD number
The same number the SEC and every state regulator already use to identify your firm. No account, no email required to see your result.
We read your Form ADV
The three items that decide FinCEN scope, plus whichever risk factors your own filing discloses: private funds, custody, wrap fee programs, foreign regulators, paid solicitors.
Get your scope profile
What applies to your firm specifically, how your peers in your state compare, and the two costs FinCEN has already put a number on.
Questions, answered
Is this legal advice?
No. This tool reads your firm’s own public Form ADV filing against the FinCEN rule’s published scope test and shows you the result. It does not replace counsel, and it makes no promise about your firm’s actual compliance status. Read the underlying rule and talk to counsel before making a decision.
Where does the data come from?
The SEC’s own public investment adviser roster (the same Form ADV data available to anyone at sec.gov), refreshed periodically. Your check shows the roster date it was read from, since Form ADV is self-reported and updated by firms on their own schedule.
My firm isn’t showing up. Why?
A few reasons: your firm is state-registered rather than SEC-registered, it reports a broker-dealer affiliation that already carries an AML program, it files as an exempt reporting adviser, or the roster simply has not caught up with a recent filing yet. None of those are checked here individually, only reported as “not in the current target list.”
Does my custodian already handle this for me?
Most advisers assume so, and FinCEN was asked directly to allow that reliance. It said no. See the full answer, with the exact quote and citation, on the dedicated page.
Do you store what I search?
No account, no database, no login. The lookup runs against a static dataset built ahead of time; the only thing recorded is an anonymous, aggregate analytics event, the same as any other pageview on this site.
Is there a paid product here?
Not yet. This is a free research tool and a set of reference pages, nothing is for sale on this site today.
Who is behind this?
Normfin is published by Neige AI, Inc., an American software company based in San Francisco. The research is compiled from primary sources, and nothing here is legal advice. Questions go to hello@normfin.com and reach the Neige AI team directly.
Read your own filing before the deadline reads it for you
One CRD number, about a minute, no account required.