Financial Services
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The Financial Crimes Enforcement Network (FinCEN) has delayed implementation of its landmark investment adviser AML rule until January 1, 2028. While the deadline has moved, regulatory expectations have not.
For registered investment advisers (RIAs), exempt reporting advisers (ERAs), and insurance companies with embedded advisory businesses, the delay presents a critical opportunity, allowing time to build an effective, risk-based AML program before compliance becomes mandatory.
In this white paper, AML and sanctions expert Elizabeth Callan examines why investment advisers remain a regulatory priority, what the delayed rule is expected to require, and how firms can use this implementation window to strengthen financial crime controls, improve risk visibility, and prepare for future regulatory scrutiny.
Investment advisers have long represented one of the largest remaining gaps in the U.S. anti-money laundering framework. Despite the implementation delay, FinCEN, the SEC, and global regulators continue to view the sector as vulnerable to sanctions evasion, illicit finance, and beneficial ownership concealment.
This white paper provides practical guidance on:
Elizabeth Callan is a recognized AML and sanctions expert with more than 25 years of experience spanning U.S. intelligence, law enforcement, financial institutions, and regulatory advisory roles. At SymphonyAI, she leads strategy and innovation focused on AI-driven financial crime prevention and risk management solutions.
Learn how leading firms are using the FinCEN implementation delay as a strategic opportunity to modernize AML controls, strengthen risk management capabilities, and prepare for the future of investment adviser regulation.
Download your copy today.
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Elizabeth Callan is a recognized leader and innovator in the fightagainst money laundering and financial crime with 25 years of experience acrossintelligence, law enforcement, and the private sector. At SymphonyAI, she is atthe forefront of redefining the future of financial crime compliance and riskmanagement. She drives strategy and innovation, developing groundbreakingAI-led, intelligence-driven solutions that are transforming how globalinstitutions detect, disrupt, and prevent money laundering, sanctions evasion,and other sophisticated financial crimes. Her work is helping to shift theindustry approach from reactive, technical compliance to proactive, risk -aligned, and highly effective risk management. Prior to SymphonyAI, Elizabethserved in the U.S. intelligence and law enforcement communities. As a SeniorIntelligence Analyst at the Central Intelligence Agency and the U.S. Departmentof the Treasury, she shaped high-impact U.S. policy and enforcement actions —including Section 311 designations — while directly advising senior officialsacross the USG, including at OFAC and FinCEN, on critical threats and nationalsecurity strategies. She also served as Intelligence Liaison and Senior Advisorto the DEA’s Special Operations Division, where she led complex, large-scalemoney laundering investigations, enhanced intelligence collection efforts,trained law enforcement agents and analysts, and forged strong internationalpartnerships. In the private sector, Elizabeth has held leadership roles in financialinstitutions and consulting firms, where she built and managed investigationsteams, designed robust AML and sanctions programs, and developed riskmanagement strategies for complex products and services. A recognized subjectmatter expert, Elizabeth teaches AML and sanctions courses at the universitylevel. She holds a master's degree in economics and analytics and ACAMS’Advanced Certification in Financial Crimes Investigations (CAMS-FCI).