With FinCEN’s final rule extending BSA obligations to RIAs and ERAs from January 1, 2026, the investment advisory landscape is entering a new era of anti-financial crime compliance.
According to Flagright, the regulatory shift moves beyond traditional fiduciary and disclosure requirements, demanding a comprehensive AML/CFT (anti-money laundering/combating the financing of terrorism) programme to tackle the evolving financial crime risks.
FinCEN requires RIAs to establish internal policies and procedures capable of identifying and preventing money laundering and terrorism financing. For firms handling diverse portfolios across complex legal and cross-border structures, outdated compliance tools are no longer sufficient.
Flagright addresses this with a centralised orchestration layer that aligns policy management across jurisdictions and investor types. Its no-code rule engine allows dynamic adaptation for bespoke structures—whether discretionary mandates or pooled vehicles—while automated controls ensure real-time integration with transaction monitoring and risk assessment workflows.
Effective AML implementation depends on a designated individual who can actively coordinate and monitor compliance. Given heightened expectations around governance and transparency, this role is now critical for regulatory alignment.
Flagright’s platform equips compliance officers with role-specific dashboards, integrated audit trails, and a configurable alert management system. These tools enable real-time oversight of compliance metrics and streamline escalation and reporting across teams.
As AML responsibilities span across portfolio managers, investor relations, and onboarding teams, consistent training is essential. However, many RIAs lack training tailored to the hybrid nature of their workforce.
Flagright solves this by providing customised risk-based training simulations drawn from real scenarios, such as abnormal redemptions or offshore transfers, ensuring staff are equipped to detect and escalate potential red flags.
To comply with FinCEN’s standards, RIAs must periodically test their AML programmes through independent reviews. These assessments must be defensible, repeatable, and regulator-ready, especially under SEC scrutiny.
Flagright offers system-generated audit logs and robust analytics to support performance evaluations. Real-time data and exportable reports provide testing teams with efficient access to metrics like SAR conversion rates and alert response efficiency.
Unlike banks, investment advisers engage in fewer transactional activities, but their exposure to financial crime remains high. From third-party redemptions to intra-account transfers, due diligence is crucial.
Flagright enables risk-based KYC processes tailored by geography and investor profile. Real-time risk scoring and anomaly detection ensure continuous monitoring, while the platform’s case management module allows for quick and accurate SAR filings with embedded templates and documentation trails.
As RIAs prepare for the BSA’s expanded scope, full-stack platforms like Flagright provide a unified solution for managing risk and demonstrating compliance—from investor onboarding to SAR submission.
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