AI tops compliance concerns for RIAs, survey finds

Artificial intelligence has emerged as the leading compliance concern for RIAs in 2025, according to the latest Investment Management Compliance Testing Survey published Tuesday.

The annual survey, now in its twentieth year, gathered responses from 577 compliance officers and professionals across firms of all sizes, highlighting a rapidly shifting regulatory landscape and the growing complexity of compliance priorities.

AI and predictive analytics were identified as the “hottest” topics by 57 percent of respondents, overtaking anti-money laundering and cybersecurity, which followed at 41% and 38%, respectively.

The survey, released by the Investment Adviser Association, ACA Group, and Yuter Compliance Consulting, found that while 40% of firms have formally adopted AI tools for internal purposes, only 5% are currently using these technologies to support client interactions. Another quarter of firms are actively exploring AI adoption, but widespread external use remains limited.

Despite the increased attention, many firms are proceeding with caution. Only 9% of those using AI mention it in their marketing materials, and nearly half of firms with AI tools in place have yet to implement formal testing or validation of the outputs from these systems. The survey also revealed that just 15% of firms have established policies and procedures to govern employee use of AI, and only 4% have set up dedicated AI governance groups.

“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,” said Carlo di Florio, president of ACA Group. "To stay ahead, compliance programs must evolve with the same speed as the risks they’re designed to manage."

Anti-money laundering has also moved up the list of priorities – 41% of participants cited it as a concern this year, compared to 6% in 2024 – driven in part by anticipated rule changes from FinCEN. However, those changes have been delayed for an additional two years, according to a Tuesday statement from the Treasury Department.

"FinCEN recognizes ... that the rule must be effectively tailored to the diverse business models and risk profiles of the investment adviser sector," the statement read, adding that "extending the effective date of the rule may help ease potential compliance costs for industry."

While 83% of firms report having some form of AML policies and procedures, only 22% have updated their policies to align with the new rule, and independent testing of these policies remains inconsistent. The survey found that 56% of firms conduct AML testing less frequently than annually, and just 19% review third parties to ensure they are completing AML reviews.

Off-channel communications, which topped the list compliance concerns in last year's survey, have dropped in priority but remain a significant area of focus. Sixty-one percent of respondents reported increased testing around electronic communications surveillance and off-channel communications, making it the most common area of increased compliance testing in 2025. This aligns with ongoing SEC rulemaking and enforcement priorities, as firms continue to monitor risks related to electronic messaging and recordkeeping. 

Marketing rule compliance also remains a challenge for many firms. Only 41% of respondents have made changes to their practices in response to the SEC’s marketing rule FAQs issued in March, and more than half believe additional relief or guidance is needed. Among those seeking further clarification, specific requests included substantiation, hypothetical performance, and institutional exceptions.

Private investments and crypto have garnered increased attention in recent weeks amid an increased push by asset managers to reach retail investors, but were apparently still low on survey participants' regulatory radar, with private funds cited by 16% and digital assets flagged by 13%.

“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 of the 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.”