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FinCEN AML scope: Illinois’s investment advisers

437 of Illinois’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 Illinois

Illinois' related-person custody share, 34.3%, lands almost exactly on the national rate of 34.3%, closer than any other state in this set. What breaks from the pattern is firm size: only 77.1% of Illinois firms have fewer than 20 people, well under the national 81.3%, meaning Illinois carries a larger share of bigger shops than most states on this list, Chicago's asset-management base rather than a state of small retail advisers.

Illinois’s numbers, in full

Firms in scope
437
Median staff
8
Fewer than 20 people
337 (77.1%)
5 people or fewer
156 (35.7%)
Custody of client cash or securities
264 (60.4%)
A related person holds custody
150 (34.3%)
Advise at least one private fund
186 (42.6%)
Median AUM
$491.9 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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