If you ever find yourself in a room full of investment advisers and are in need of a conversation starter, ask the following question: “Who believes that anti-money laundering (“AML”) regulations don’t apply to investment advisers?” The likely outcome will be a spirited debate with some taking the position that AML regulations do not apply to investment advisers, only to broker-dealers, while others may argue that AML safeguards are part of their fiduciary duty as an investment adviser and therefore there is an obligation to develop AML procedures. The answer to the question is the focus of this article and will discuss current anti-money laundering regulations, duties owed by investment advisers and the anticipated changes that may be occurring in this area in the not-too-distant future.