The one-to-five-person advisory firm
FinCEN considered and declined a size exemption for advisers with fewer than 20 or 100 employees. The same four-pillar mandate applies, on a compliance budget built for neither.
See how it appliesYour custodian’s AML program does not cover you
FinCEN’s rule gives every SEC-registered adviser until January 1, 2028 to build an AML program of their own. That includes firms with no compliance headcount: a written AML program, a named compliance officer, staff training, and an independent test.
Quick answer
- FinCEN’s AML rule reaches every SEC-registered investment adviser by January 1, 2028, with zero size exemptions granted in the final rule.
- Four required pillars: a written AML program (internal policies, procedures and controls), a designated compliance officer, staff training, and an independent test run every year.
- FinCEN’s own estimates: about 120 hours to build the program and roughly $17,000 a year for the independent test. Praxtrust builds it at a fixed price, not a monthly retainer.
- No card, no payment tunnel
- No form: nothing you type is stored
- Informs on the mandate, not legal advice
Program build
The pillars the rule requires
- A written AML program: internal policies, procedures and controls
- A designated compliance officer
- Staff training
- An independent test
- FinCEN’s compliance deadline (91 FR 36)
- Jan 1, 2028
- FinCEN’s own estimate of the average annual test cost
- $17,000
- FinCEN’s own estimate of the work to build the program
- 120 hours
- size exemptions granted in the final rule
- 0
Who this is for
Advisers to private funds
Registering as an adviser to a private fund does not create a separate compliance track. A fund administrator’s own diligence does not move the adviser’s own AML obligation.
See how it appliesAdvisers with custody of client assets
FinCEN was asked to let advisers rely on a qualified custodian’s own AML checks instead, and refused. The Custody Rule and the AML rule are two separate obligations.
See how it appliesAdvisers with no broker-dealer affiliation
No affiliated BD means no inherited AML infrastructure. Our review of SEC Form ADV data counts 11,223 registered advisers in exactly this position.
See how it appliesHow the engagement runs
A short conversation
We map your firm’s structure: employee count, custody status, fund structures if any, and whatever compliance process already exists, however informal.
The program, delivered
A written AML program, the compliance officer designation, and staff training, calibrated to your firm and delivered at a fixed price, not a monthly retainer.
The annual independent test
Once the program is live, Praxtrust runs the independent test the rule requires every year. The rule’s only requirement for the tester is independence from the function tested; no certification is mandated.
What it costs
An outsourced compliance officer for a firm this size runs $1,500 to $6,000 a month, plus $3,000 to $20,000 to stand up a program from scratch. Praxtrust is a fixed-price alternative to that, not a subscription.
The program build is $8,000, the annual independent test is $17,000 a year, and the two together at signing are $23,000 for the first year: half up front, the rest when the written program is delivered.
A materially unusual firm structure, custody status, or compliance stack can still move the final invoice. No card, no tunnel, a conversation first.
Not sure the rule even reaches your firm? Check your CRD against the SEC roster, free, at normfin.com. It reads your own public filing and takes no email.
Questions, answered
Does the FinCEN rule really apply to a firm as small as mine?
Yes. FinCEN considered an exemption for advisers with fewer than 20 or 100 employees and declined it in the final rule: every SEC-registered investment adviser is covered, regardless of headcount.
Isn’t my custodian already handling AML for me?
No. A commenter asked FinCEN to let advisers rely on a custodian’s or other intermediary’s AML measures instead of running their own program. FinCEN declined, on the record: “the adviser will remain responsible for overall compliance with these requirements” (89 FR 72156, p. 72188).
What exactly is the deadline?
January 1, 2028. The rule was finalized September 4, 2024 (89 FR 72156) with an earlier compliance date, which FinCEN pushed to 2028 in a separate rule published January 2, 2026 (91 FR 36). A postponement, not a cancellation.
Does the independent tester need a specific certification?
No. The rule only requires that the person or firm performing the test be independent of the function being tested. There is no mandated credential, which is what makes an external, fixed-price annual test practical for a small firm.
What does the fixed-price pack actually include?
The pillars the rule requires: a written AML program, a designated compliance officer, staff training, and your firm queued up for the first year of independent testing. See “What it costs” for the order of magnitude; the exact figure follows the initial conversation.
Is this legal advice?
No. Praxtrust explains what FinCEN’s rule requires and provides compliance program development and independent testing services; it does not provide legal advice. For an opinion on your firm’s specific obligations, talk to counsel.
Who is behind this?
Praxtrust is built and operated by Neige AI, Inc., a Delaware (USA) corporation, 2261 Market St STE 46015, San Francisco, CA 94114. Praxtrust informs on the AML mandate; it does not provide legal advice. Questions go to hello@praxtrust.com and reach the Neige AI team directly.
Build the program before the deadline decides it for you
The four-pillar mandate, a fixed-price build, and the annual test the rule requires. One conversation to start.
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