This article examines the ways RIAs, multi-family offices and others in the wealth management space are preparing for new anti-money laundering rules and other regulations looming over the horizon.

With a combination of trepidation and confidence, RIAs are gearing up to comply (see previous article) with the host of sweeping new requirements for the Treasury Department’s new Anti-Money Laundering (AML) rule set to take effect on January 1, 2026.

Many firms took a wait-and-see approach to the new AML rule for the first half of the year, expressing skepticism about whether the rule would actually take effect on time, according to Patrick Hunt, CEO of  compliance software provider Smartria.

But “the tenor changed” after the July 4 holiday, and wealth managers are now stepping up preparations to comply with anti-money laundering and countering the financing of terrorism (CFT) requirements by the new year, Hunt said.

The compliance group at Pathstone is making implementating the rule “one of its highest priorities of the year,” said Matt Fleissig, CEO of the multifamily office. Perigon Wealth Management is “currently reviewing internal policies and procedures and enhancing existing controls to ensure full compliance by the effective date,” according to general counsel and chief compliance officer Jonathan Robbins.

Hurdles ahead
How challenging will implementating the sweeping new AML rule be for RIAs?

Parts of the AML rule require “basic blocking-and-tackling that chief compliance officers are very familiar with,” including having updated policies and procedures and integrating tasks and documentation into workflows, Hunt said.

But other requirements, like suspicious activity reports, will be more demanding, according to Hunt and RIA executives.

Firms that already have accounts, transactions and holdings as part of their compliance programs for employee and client trade oversight “have a leg up on others with regard to SARs,” Hunt said.

But even large multi-family offices will have to make adjustments to accommodate SARs and CTR reporting requirements. Eton Advisors Group is enhancing compliance training “to ensure staff are aware of the variety of red flags that will trigger the need to notify the AML officer,” said Brian Hughes, president of the MFO.

Employee training will be “the most formidable challenge,” for large RIAs, agreed Fleissig. “While robust technology solutions are incredibly important and helpful, educating employes about identifying and reporting suspicious activities as well as avoiding human error is critical to a successful AML/CFT program.”

How to file a SAR
Translating new requirements and policies into day-to-day operational changes will also be key, said Jennifer Szaro, chief compliance officer of the XML Financial Group. 

For example, learning how to file a SAR “starts with creating an account on the BSE E-filing system using a Log.in gov account,” Szaro explained. “Then review a blank SAR filing to see the types of situations reflected and the information collected. Work backwards with your policies.”

Evolving current compliance requirements “to encompass broader obligations,” will present Perigon and other RIAs with a major challenge, said Robbins. “This requires careful interpretation of requirements and coordination across compliance, operations advisory and legal teams to ensure we’re not just checking boxes, but building something sustainable and compliant.”

“This is a major operational and compliance lift”
How big a lift will AML implementation be for RIAs?

The overall cost for firms with a strong compliance culture, broad employee engagement and experience with integrating trading data “should not be terribly significant,” Hunt maintained. 

Advisors weren’t so sure. “This is a major operational and compliance lift for firms,” said XML’s Szaro. “The independent AML audit requirement will likely require hiring an outside consulting firm to conduct the audit.” Indeed, Eton Advisors will be adding a line item to its budget to independently test the overall effectiveness of its AML compliance program, Hughes said.

As the deadline approaches, RIAs say they would like more guidance from the SEC and the Treasury Department “outlining expectations surrounding the rule,” as Robbins put it. Although the compliance date is less than six months away, the Customer Identification Program rules have not yet been finalized, Hughes noted. “Getting this information will be necessary to finalize our implementation,” he said.

Miami lessons
As it happens, wealth managers in the Miami, Florida market working with offshore clients have had years of experience with anti-money laundering rules and issues. 

As governments around the world increasingly exchange information, “more and more coordination and cooperation is expected,” said Miguel Sosa, founding partner of Premia Global Advisors in Coral Gables. “The sources of challenges that affect AML regulations are also changing.

We are seeing more sophisticated activity and money movements. The proliferation of cybercurrency and exchanges has put pressure on how regulators monitor AML activity.”

“Positive for the industry”
Despite the work involved, RIAs are generally sanguine about the new AML rule.

“While the rule introduces new requirements, it aligns with our broader commitment to maintaining high standards of integrity,” said Robbins. Despite concerns about the increased complexities and costs the rule brings, the protection it brings investors makes it a “positive for the industry,” Hughes added.

Fleissig points out that “as fiduciaries, it is imperative as advisors that we play our part in combating financial crimes including money laundering and terrorist financing.”

What’s more, having a dynamic understanding of anti-money laundering regulations “helps to provide for better advice,” Sosa said. “International clients come to US advisors seeking their guidance and part of this guidance is to share what and how our regulations may affect their money movements. It’s key to understanding the relationship with each client.”

For an AML compliance cheat sheet, see here.