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 pageEnter your CRD number. We read your firm's own public Form ADV filing and show you exactly which parts of the rule apply, plus the one thing most advisers wrongly assume their custodian already handles.
11,223 SEC-registered firms indexed, from the SEC roster dated 2026-08-03. No account, nothing stored.
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.
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.
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.
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 three lines on Form ADV that decide it, and why FinCEN refused to exempt small firms by headcount.
Read the pageThe most common assumption an adviser makes, and FinCEN's own written refusal to let you rely on it.
Read the pageFinCEN's own estimate for the one-time build, and the recurring annual cost almost nobody quotes.
Read the pageWhat it has to cover, who is allowed to perform it, and how often.
Read the pageThe one delay so far, why a delay is not a withdrawal, and the deregulatory review FinCEN itself announced.
Read the pageThe same number the SEC and every state regulator already use to identify your firm. No account, no email required to see your result.
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.
What applies to your firm specifically, how your peers in your state compare, and the two costs FinCEN has already put a number on.
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.
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.
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."
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.
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.
Not yet. This is a free research tool and a set of reference pages, nothing is for sale on this site today.
One CRD number, about a minute, no account required.
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