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FinCEN AML scope: Massachusetts’s investment advisers

438 of Massachusetts’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 Massachusetts

A median Massachusetts firm in scope manages $704.0 million, the second-highest median AUM among the ten largest states, behind only New York. Its median staff of 9 also runs above the national median of 7, and 47.5% of its firms advise at least one private fund against a national 39.9%. Massachusetts firms in this population skew larger and more fund-exposed than most of the other nine states here.

Massachusetts’s numbers, in full

Firms in scope
438
Median staff
9
Fewer than 20 people
319 (72.8%)
5 people or fewer
139 (31.7%)
Custody of client cash or securities
282 (64.4%)
A related person holds custody
207 (47.3%)
Advise at least one private fund
208 (47.5%)
Median AUM
$704.0 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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