Artificial Intelligence Tops Compliance Priorities for Investment Managers in 2025

Strategic Insights -

The 2025 Investment Management Compliance Testing (IMCT) Survey, released by Investment Adviser Association, ACA Group, and Yuter Compliance Consulting, reveals that Artificial Intelligence (AI) has emerged as the leading priority among compliance officers. 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.

Compliance officers are prioritizing testing in areas closely aligned 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%). Notably, the majority of respondents reported increased compliance testing in all areas, with some areas seeing significant increases.

The 2025 IMCT Survey also highlights cautious but rising adoption of AI among investment managers. While only 5% of firms use AI to support client interactions, 40% have formally adopted AI tools for internal use cases, and another 25% are actively exploring AI adoption. However, 44% of firms that have adopted AI tools have no formal testing or validation of the outputs from their AI tools.

Key Takeaways:

  • Articificial Intelligence (AI) has emerged as the leading priority among compliance officers, with 57% of firms prioritizing AI usage.
  • Anti-Money Laundering (AML) readiness is the second-largest priority, with 41% of firms citing AML readiness as a concern.
  • Cybersecurity controls are the third-largest priority, with 38% of firms citing cybersecurity controls as a concern.
  • Marketing rule compliance, electronic communication surveillance off-channel communications, private funds, digital assets, vendor due diligence, are also among the top compliance hot topics for 2025.
  • The IMCT Survey revealed increased testing priorities for CCOs, with top areas including electronic communication surveillance/off-channel communications (61%), cybersecurity (55%), advertising/marketing (48%), and AI (46%).
  • The majority of respondents reported increased testing in all areas, with some areas seeing significant increases.

Statistics:

  • 57% of firms prioritize AI usage.
  • 41% of firms prioritize AML readiness.
  • 38% of firms prioritize cybersecurity controls.
  • 36% of firms prioritize marketing rule compliance.
  • 61% of firms increase testing in electronic communication surveillance/off-channel communications.
  • 55% of firms increase testing in cybersecurity.
  • 48% of firms increase testing in advertising/marketing.
  • 46% of firms increase testing in AI.
  • 40% of firms have formally adopted AI tools for internal use cases.
  • 25% of firms are actively exploring AI adoption.
  • 44% of firms that have adopted AI tools have no formal testing or validation of the outputs from their AI tools.

Sources:

  • Investment Adviser Association, ACA Group, and Yuter Compliance Consulting (2025 IMCT Survey)
  • SEC's rulemaking and enforcement priorities
  • Amy Yuter, Managing Principal of Yuter Compliance Consulting
  • Carlo di Florio, President of ACA Group
  • Karen Barr, President and CEO, Investment Adviser Association