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FinCEN AML scope: Colorado’s investment advisers

253 of Colorado’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 Colorado

A median Colorado firm in scope manages $315.3 million, the lowest median AUM among the ten largest states, and 44.7% of its firms have 5 people or fewer, the second-highest concentration of small firms in this group, both against a national median of $431.1 million and a national 5-or-fewer share of 41.3%. Colorado's in-scope firms run leaner than almost anywhere else on this list.

Colorado’s numbers, in full

Firms in scope
253
Median staff
6
Fewer than 20 people
219 (86.6%)
5 people or fewer
113 (44.7%)
Custody of client cash or securities
164 (64.8%)
A related person holds custody
63 (24.9%)
Advise at least one private fund
77 (30.4%)
Median AUM
$315.3 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.

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