
Here are three takeaways from June's session:
AML compliance is non-negotiable
With the January 1, 2026, AML ruling deadline fast approaching*, the council emphasized the importance of assessing compliance readiness now. As the group unanimously stressed: "Hope is not a strategy."
Readiness assessments, policy development, vendor selection, and internal approvals all take time. Further delays in preparation could leave firms at risk of enforcement actions.
"If you haven't started preparing, you're already late...[there are] decisions that you should have already been thinking about." - Dan Rothenberg
*On July 21st, the U.S. Treasury issued a release stating that FinCEN anticipates delaying the effective date of the IA AML Rule from January 1, 2026, until January 1, 2028.
Retail investors’ growing role
The shift towards retail is no longer theoretical: Interval funds, tender offer funds, and even 401(k) inclusion of alternatives are gaining serious traction. Firms must strengthen investor education, disclosure, and suitability processes now because it'll be the first movers will win. Being early to market with compliant, retail-ready products will create momentum and help capture capital, so streamlining reporting and technology is crucial for GPs who want to avoid operational inefficiencies as they scale.
"We're already seeing an expansion into retail. That's exciting [but] it definitely creates additional regulatory burdens that go hand-in-hand with opening up to retail investors." - Michael McVickar
Regulatory fluidity requires vigilance
The withdrawal of certain Gensler-era rules does not automatically mean we're in an era of deregulation. Core investor protections remain and transparency on fees, conflicts, and performance claims is still essential. Fiduciary duties and antifraud provisions are still very much in play, especially as retail access expands. Meanwhile, tax code changes (e.g., QSBS updates) create both opportunities and new compliance dimensions. And with the SEC and FinCEN moving on different timelines, regulatory coordination is fragmented.
"Prepare for the current compliance date while watching for potential extensions or coordination between FinCEN and the SEC. But you can't be complacent. You've got to be ready.” - Carlo di Florio