FinCEN AML scope: California’s investment advisers
1,343 of California’s SEC-registered investment advisers clear FinCEN’s three-part AML scope test, from the SEC’s own roster dated 2026-10-02. See the exact filter and sources for how that population is defined.
What stands out in California
California is the second-largest state on this list by firm count, and its numbers track the national baseline closer than any other state here: a median staff of 7, equal to the national median, a custody share of 59.3% against a national 56.3%, 41.8% of firms with 5 people or fewer against a national 41.3%, and 7.1% of firms in a wrap fee program against a national 7.4%. On almost every measure here, California sits within a few points of the whole country.
California’s numbers, in full
- Firms in scope
- 1,343
- Median staff
- 7
- Fewer than 20 people
- 1,075 (80.0%)
- 5 people or fewer
- 562 (41.8%)
- Custody of client cash or securities
- 797 (59.3%)
- A related person holds custody
- 491 (36.6%)
- Advise at least one private fund
- 600 (44.7%)
- Median AUM
- $502.5 million
This page is independent research, not legal advice, computed from the SEC’s own public roster of investment advisers. See the method and sources. Verify anything load-bearing against the Federal Register text itself before acting on it. The custody figures above count roster disclosures only. Whether a qualified custodian’s own AML program covers the adviser is a separate question, answered on its own page.