While there's a new chief at the Securities and Exchange Commission, the message from SEC staff is to "keep your foot on the compliance pedal," according to the annual Investment Management Compliance Testing survey.

The survey was just released by the Investment Adviser Association, ACA Group and Yuter Compliance Consulting.

The hot compliance areas in 2025 closely align with the SEC’s exam, enforcement and rulemaking priorities, according to the survey.

“This year’s survey highlights a pivotal shift in compliance priorities," said Carlo di Florio, president of ACA Group, in a statement. "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.”

Results of this year's survey were conducted before Treasury announced Monday that it has postponed the effective date for the anti-money laundering rule for investment advisors until Jan. 1, 2028, as it takes a "broad review" of the rule.

With the delay of the AML rule’s implementation, "it is clear that the Department of Treasury was aware of the concerns that the industry had about the rule (e.g., the rule’s applicability to low-risk advisers, the burden on firms whose custodians already perform AML checks, and the need to balance the costs & benefits of many of the rule’s new requirements)," Aaron Pinnick, senior manager of Thought Leadership at ACA, told ThinkAdvisor in an email. While the rule has been delayed, "firms should still plan and prepare for its implementation."

Compliance professionals at 577 investment advisor firms participated in the survey, which found that 45% of firms exceeded their compliance budget in 2024.

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," the survey points out. The 2025 survey also found that the majority of chief compliance officers (63%) continue to wear more than one hat, with 17% also serving in some legal capacity.

See the gallery for the five hottest compliance topics of 2025, according to the survey.

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