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Survey: Artificial Intelligence Identified as Top Compliance Concern Among Investment Adviser Firms

Anti-Money Laundering and Cybersecurity follow closely behind

Artificial Intelligence (AI) has ranked as the leading priority among compliance officers, according to the 2025 Investment Management Compliance Testing (IMCT) Survey, released today by Investment Adviser Association, ACA Group, and Yuter Compliance Consulting.

Now in its 20th year, the IMCT Survey remains the industry’s most comprehensive benchmark for compliance testing practices and priorities.

This year’s results highlight a rapidly evolving regulatory landscape, with AI, Anti-Money Laundering (AML), and cybersecurity emerging as the top three “hot” compliance topics. These areas closely align with the SEC’s exam, enforcement, and rulemaking priorities. The full list of hot compliance topics for 2025 includes:

  • AI Usage (57%)
  • AML Readiness (41%)
  • Cybersecurity Controls (38%)
  • Marketing Rule Compliance (36%)
  • Electronic Communication Surveillance/Off-Channel Communications (23%)
  • Private Funds (16%)
  • Digital Assets (13%)
  • Vendor Due Diligence (11%)

Notable Findings

The 2025 IMCT Survey, conducted online throughout May, covered a wide range of topics. In addition to the top compliance hot topics, the IMCT Survey provided notable findings on subjects such as:

  • AI adoption is cautious but rising. While only 5% of firms use AI to support client interactions, 40% of firms have formally adopted AI tools for internal use cases, and another 25% are actively exploring AI adoption. 46% of respondents reported increased compliance testing around AI—up from 32% last year, but 44% of firms that have adopted AI tools have no formal testing or validation of the outputs from their AI tools.
  • AML moves to the forefront. With FinCEN’s final rule on the horizon1, AML jumped to the #2 spot among top compliance concerns. While 83% of firms have some AML policies, only 22% have updated their policies to align with the new rule, and independent testing of these policies remains inconsistent.
  • The top areas of increased testing align with SEC focus areas: The IMCT Survey revealed the following testing priorities for CCOs: #1 Electronic Communication Surveillance/Off-Channel Communications (61%), #2 Cybersecurity (55%), #3 Advertising/Marketing (48%), #4 AI (46%), #5 Vendor Due Diligence (42%). These top areas are in line with SEC rulemaking and enforcement priorities, reflecting a proactive approach across the industry — a trend that has continued over the past several years. Notably, the majority of respondents did not decrease testing in any area.

“It’s incredible to see how much the industry continues to benefit from the IMCT Survey with participants consistently reporting its high value in strengthening their compliance programs. Launched 20 years ago from a compliance conference session on testing, the IMCT Survey has grown into the leading resource for CCOs to benchmark their programs against peers. It unites the industry around shared standards and best practices, enabling us to support one another in building strong compliance frameworks, meeting regulatory expectations, and developing reasonable policies and procedures tailored to our unique business models,” shared Amy Yuter, Managing Principal of Yuter Compliance Consulting.

Carlo di Florio, President of ACA Group, added, “This year’s survey highlights a pivotal shift in compliance priorities. AI has rapidly ascended to the top of the agenda, while cybersecurity and AML remain critical areas of focus. The data shows that firms are responding with increased testing and mock exams, but gaps remain, particularly in AI governance, vendor oversight, and whistleblower protections. To stay ahead, compliance programs must evolve with the same speed as the risks they’re designed to manage.”

“Investment advisers are proactively enhancing their compliance frameworks to stay ahead of dynamic regulatory developments and emerging risks, while maintaining a sharp focus on their foundational compliance obligations," said Karen Barr, President and CEO, Investment Adviser Association. "The survey underscores an increase in testing across critical areas such as Artificial Intelligence and AML readiness, illustrating the heightened pressures and expanding scope of responsibilities facing today’s compliance officers.”

About the Survey Respondents

Compliance professionals at 577 investment adviser firms participated in the survey. All firm sizes were represented – with 23% of respondents managing less than $1 billion in assets, 43% managing $1 billion to $10 billion, and 34% managing more than $10 billion. Close to half (41%) of responding firms reported having between 11 and 50 employees, consistent with industry data showing that most investment advisers are small- to mid-sized businesses. This year’s survey also revealed that the majority of CCOs (63%) continue to wear more than one hat (with 17% also serving in some legal capacity).

Services provided by responding firms spanned the full range of client types, including retail individuals with a typical account size of $1 million or less (30%), private funds (63%), ERISA assets/pension consultants (38%), institutional clients (54%), and high net worth individuals (52%).

Full results of the 2025 Investment Management Compliance Testing Survey are available on the IAA’s, ACA’s, and YCC’s websites and here.

About the Investment Adviser Association

The Investment Adviser Association (IAA) is the leading trade association representing the interests of fiduciary investment advisers. The IAA’s member firms collectively manage more than $35 trillion in assets for a wide variety of institutional and individual investors. In addition to serving as the voice of the advisory profession on Capitol Hill and before the SEC, DOL, CFTC and other U.S. and international regulators, the IAA provides extensive practical and educational resources to its membership. For more information, visit www.investmentadviser.org or follow us on LinkedIn, Twitter and YouTube.

About ACA Group

ACA Group (ACA) is the leading governance, risk, and compliance (GRC) advisor in financial services. For over 20 years, we’ve empowered our clients to launch, grow, and protect their business. Our global team of 1,400 employees includes former regulators and practitioners with a deep understanding of the regulatory landscape. Our innovative approach integrates advisory, managed services, distribution solutions, and analytics with our ComplianceAlpha® technology platform. For more information, visit https://www.acaglobal.com.

About Yuter Compliance Consulting

Yuter Compliance Consulting (YCC) is an internationally recognized boutique compliance consulting firm offering consultation and support services trusted by the industry’s chief compliance officers. Amy Yuter, Managing Principal of Yuter Compliance Consulting, has over 30 years of industry, consultation and SEC regulatory experience in overseeing investment advisers, investment companies, public companies, broker-dealers, and private funds. Amy is the founder of The Philadelphia Compliance Roundtable and the Investment Management Compliance Testing Survey. Yuter Compliance Consulting partners with clients to provide personalized consultation and support to enhance compliance resources and improve compliance programs. For more information, visit www.yutercompliance.com.

Notes:

Due to rounding, the sum of these results does not equal 100%.

1 On July 21, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced the postponement of the effective date of the final IA AML rule from January 1, 2026, until January 1, 2028.

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