What You Need to Know: How the FinCEN Final Rule Impacts Registered Investment Advisers (RIAs)

2026 will be here in a flash, and for Registered Investment Advisers (RIAs), this means the need to comply with AML regulations. The Financial Crimes Enforcement Network (FinCEN) recently introduced the “Final Rule,” adding new compliance requirements for RIAs. Now classified as “financial institutions” under the Bank Secrecy Act (BSA), RIAs must implement Anti-Money Laundering (AML) programs. This requires them to perform thorough KYC on their customers, monitoring their ongoing activity, including transactions.  and report suspicious activities. This shift means increased operational pressure, tighter regulatory oversight and reporting demands, and a clear deadline—by January 1, 2026, RIAs must fully comply. Here’s what RIAs need to know to prepare.

Key Compliance Areas Under the Final Rule

To comply with FinCEN’s Final Rule, RIAs need a solid AML compliance program focused on a few key areas:

• Know Your Customer (KYC): Conducting thorough KYC checks on clients allows RIAs to identify and manage risks early. Not just during onboarding but also throughout the lifecycle.
• Suspicious Activity Monitoring: Monitoring client transactions closely to identify and detect activity that is suspicious or activity which exceeds currency reporting requirements.
• Screening Procedures: Continually monitor customers against watchlists to identify additional customer risks, including sanctions, Politically Exposed Persons (PEP) status and any identified adverse media.
• Governance: Strong governance and audit process for thorough transparency and accountability across the AML program, helping to provide management oversight and appropriate evidence during audits and examinations.

Why KYC Procedures Are Essential

An effective Know Your Customer (KYC) process is central to risk management. Verifying customer identities, monitoring and understanding risk throughout the lifecycle enables RIAs to catch issues early, manage this risk and maintain compliance. By continually monitoring customer profiles with internal and external data, RIAs can build an accurate and comprehensive profile that supports smarter risk management and decision-making

Monitoring and Reporting: A Core Compliance Requirement

Transaction monitoring lies at the heart of AML compliance. With sophisticated tools, RIAs can spot suspicious transactions, meet regulatory requirements, and avoid penalties. Effective transaction monitoring includes prioritizing high-risk alerts, streamlining investigations, and ensuring accurate, timely reporting for regulators.

Screening with Precision

Effective screening identifies high-risk clients, including those on global watchlists or those associated with known risks. Advanced screening tools help RIAs keep up by reducing false positives and improving match accuracy. With flexible screening options—real-time, batch, or on-demand—RIAs can adapt to the evolving geopolitical landscape and meet regulatory requirements.

Preparing for the FinCEN Compliance Deadline

With the compliance deadline approaching, RIAs need to act fast to build a resilient AML strategy that includes robust KYC, precise screening, ongoing monitoring and automated reporting. NICE Actimize offers a comprehensive suite of solutions to support these requirements, so RIAs can stay proactive and compliant as regulatory expectations evolve.

Download the RIA eBook to navigate FinCEN’s Final Rule and get detailed guidance on staying compliant by 2026.