What does the AML rule delay really mean for investment advisers, and what should firms be doing now? In this episode of AML Uncovered, Mark is joined by Brett Manwaring, Advisory Lead at Sigma 360, as they unpack why FinCEN pushed back the compliance deadline, the real costs and governance challenges behind AML programs, how firms should be thinking about direct and indirect financial crime risk, and why getting ahead of compliance is critical even with the extra time.
Topics covered include:
[01:05] Intro to Brett Manwaring from Sigma 360. Mark and Brett discuss Brett's background and Sigma 360's role in financial technology for risk mitigation.
[03:04] Brett shares his perspective on the recent delay of the investment advisor AML rule from 2026 to 2028, highlighting the challenges faced by smaller IRAs and the potential financial and operational impacts.
[06:13] The discussion delves into the essential elements of AML programs, such as governance, compliance officer designation, and ongoing customer due diligence. Brett and Mark emphasize the importance of a risk-based approach.
[20:27] Brett discusses the critical role of financial technology in AML programs, mentioning tools that aid in monitoring direct and indirect risks. They elaborate on the value of AI and data integration for efficient risk management.
[24:52] The conversation shifts to the evolving regulatory landscape, touching on the importance of ongoing governance and risk assessment in AML compliance.
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