AML compliance with no broker-dealer affiliation to lean on
An adviser affiliated with a broker-dealer sits inside a firm that already runs AML controls under FINRA and Bank Secrecy Act rules. An independent adviser has none of that infrastructure to inherit, and FinCEN's rule does not adjust for it.
Independent means fully on the hook
Our review of SEC Form ADV data counts 11,223 SEC-registered advisers carrying no broker-dealer signal at all: no affiliated BD, no inherited AML program, no compliance department built for a different regulator's exam. Each one owes the same four pillars as a wirehouse-affiliated adviser, from a standing start.
No reliance, by FinCEN's own words
FinCEN considered letting an adviser lean on a financial institution's or intermediary's existing AML measures and declined, on the record: "the adviser will remain responsible for overall compliance with these requirements" (89 FR 72156, p. 72188). For an adviser with no affiliated BD, there was never a program to lean on in the first place.
Building the program from zero, at a fixed price
The pack is the written AML program, the compliance officer designation, and staff training, built for a firm with no existing AML infrastructure to extend. The independent test follows every year after, satisfying the rule's only real requirement for the tester: independence from the function being tested.