AML & Financial Crime
An effective anti-money laundering (AML) framework is essential to safeguarding the integrity of the U.S. capital markets and the global financial system. Broker-dealers and other financial institutions play a unique and vital role in detecting and deterring illicit finance — helping ensure that our markets remain trusted, transparent, and resilient.
Across the industry, AML and financial crime professionals conduct extensive surveillance of fund movements, monitor transactions, verify customer identities, and analyze complex activity to identify suspicious patterns. Through these efforts, the securities industry contributes significantly to law enforcement investigations, filing thousands of Suspicious Activity Reports (SARs) each year that provide critical leads to combat financial crime.
Key Focus Areas
Implementing the AML Act of 2020
Anti-Money Laundering Act of 2020, which became law on January 1, 2021, is the most significant piece of AML-related legislation since the USA PATRIOT Act of 2001. The Act is designed to streamline regulatory requirements, enhance coordination among agencies, and direct financial institutions to focus resources on the highest-risk activities and threats.
SIFMA is helping member firms incorporate the Act’s provisions into their risk-based compliance programs, and we continue to engage with the U.S. Department of the Treasury, FinCEN, and other regulators to ensure the Act’s implementation aligns with its original purpose — modernizing outdated rules that often divert resources from areas of highest risk.
Responding to FinCEN’s 2024 Investment Adviser Rule
In September 2024, FinCEN adopted a final rule applying AML requirements to investment advisers. The rule — effective January 1, 2026 — requires covered advisers to establish risk-based AML programs, designate a compliance officer, conduct training, arrange independent program reviews, maintain fund transmittal records, and file SARs.
While FinCEN tailored certain provisions, others do not sufficiently reflect the unique structure of advisory businesses. SIFMA has urged regulators to provide additional guidance or revise the rule to reduce unnecessary compliance burdens. FinCEN has also proposed Customer Identification Program (CIP) requirements for advisers, which remain pending. If CIP rules are not finalized in time, SIFMA recommends extending the AML rule’s compliance date to allow advisers to build robust, compliant programs.
Addressing Emerging Risks
As new products and business lines evolve, AML programs must adapt to emerging threats. Areas such as the marijuana industry, digital assets, and cross-border fintech platforms present novel risks that require thoughtful oversight and interagency coordination.
SIFMA continues to assist members in navigating these evolving risks, sharing information, and promoting best practices to ensure compliance and resilience in an increasingly complex landscape.
Advancing Collaboration and Information Sharing
The securities industry dedicates substantial time, expertise, and resources to detecting and preventing financial crime. SIFMA fosters a collaborative environment through working groups, roundtables, and joint initiatives with regulators and law enforcement agencies to strengthen the collective fight against illicit finance.
Enhanced information sharing — both within the private sector and between firms and government — remains a cornerstone of an effective AML regime.
The Bottom Line
Protecting our financial system from illicit finance requires vigilance, coordination, and modernization. SIFMA and its members are committed to advancing an AML framework that is risk-based, technology-enabled, and forward-looking, ensuring that U.S. markets remain the safest, most transparent, and most trusted in the world.
