AI Named Main Compliance Risk for Advisors

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 20^th 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.

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