The priorities cover a broad range of issues, including fiduciary obligations, complex investment products, cybersecurity and evolving market infrastructure. For compliance teams, several areas stand out: the effectiveness of compliance programs, conflicts of interest, anti-money laundering (AML) controls and the increasing use of advanced technology across financial services.
Key Highlights
- Compliance program effectiveness remains a fundamental part of the examination process.
- Super intelligence (SI) receives increased attention, including its use in compliance monitoring, AML, trading and fraud prevention.
- AML examinations will continue to focus on risk-based programs, customer due diligence and SAR filing obligations.
- Conflicts of interest remain a priority for both investment advisers and broker-dealers.
- Cybersecurity, digital assets, tokenization and evolving market infrastructure remain areas to watch.
Compliance Program Effectiveness Remains Fundamental
For investment advisers, the SEC priorities note that the evaluation of compliance program effectiveness remains a critical element of the examination process.
Examiners will continue to review key components of compliance programs across areas including marketing, valuation, trading, portfolio management, disclosures, filings and custody. They will also typically review advisers' annual compliance reviews and assess whether policies and procedures are appropriately designed for the firm's operations and conflicts of interest—and whether those policies and procedures are actually being implemented effectively.
The priorities also highlight the need for compliance programs to keep pace with changes in the business. The SEC specifically calls out advisers that have changed business models, moved into new asset classes or services, completed mergers or acquisitions, or operate across geographically dispersed branch offices. Examiners will assess whether compliance programs have adapted to those changes and addressed resulting conflicts of interest.
The focus goes beyond having policies and procedures in place. Firms need to be able to demonstrate that compliance programs reflect the risks and activities present across the business and that controls are working as intended.
Watch the webinar Beyond the Annual Review: Keeping Policies and Compliance Current Amid Regulatory Change with analyst Michael Rasmussen from GRC 2020.
Super Intelligence Moves Further Into the Compliance Spotlight
Emerging technology has featured in SEC examination priorities for several years. For 2027, however, the Division specifically identifies the use of super intelligence (SI) in core business operations and systems.
The 2027 SEC priorities note that registrants are increasingly incorporating SI into their businesses, including generative SI tools supporting research, drafting, coding, client communications, advisory and portfolio management functions, and compliance monitoring and surveillance.
The document highlights that examiners will prioritize policies and procedures for monitoring SI, including its use in:
- Fraud prevention and detection
- Back-office operations
- AML compliance
- Regulation Best Interest compliance
- Trading functions
The SEC will also examine how firms are preparing for SI-related cyber threats, including SI-generated phishing and synthetic or deepfake voice and video used for social engineering.
The terminology may be new, but the underlying regulatory expectation is familiar. As advanced technologies become embedded in more processes, firms still need appropriate policies, controls and oversight—and need to understand where the technology is being used and the risks it creates.
Read our Guide to Responsible AI for Compliance Officers for more on governance, risk management and oversight as firms incorporate AI into compliance.
AML Remains a Priority for Broker-Dealers
AML remains a significant area of focus for broker-dealers in 2027.
Examiners will assess whether firms are appropriately tailoring and updating their AML programs to their business models and risk profiles. The SEC specifically highlights risks associated with omnibus accounts maintained for foreign financial institutions and significant changes in a firm's business.
Reviews will also cover independent testing, ongoing customer due diligence, Suspicious Activity Report (SAR) filing obligations and risks associated with trading in foreign-based companies and potential cross-border market manipulation and fraud.
In addition, the priorities identify the use of SI for AML compliance as an area where examiners will review firms' policies and procedures.
Conflicts of Interest Remain Central
Conflicts of interest continue to feature prominently across the SEC priorities, as they have in years past. Read about 2025 and 2026 SEC Examination Priorities.
For investment advisers, the SEC will focus on economic conflicts that could affect the impartiality of investment advice, including conflicts involving fees and expenses, cash management and other financial arrangements.
For broker-dealers, examinations under Regulation Best Interest will consider conflict identification and mitigation practices. Dual registrants also remain an examination priority, including how firms identify, mitigate or eliminate conflicts arising from compensation and other financial incentives.
These areas reinforce the importance of having visibility across activities and relationships that can create conflicts—and maintaining a clear record of how potential conflicts were identified, reviewed and addressed.
Other Areas of SEC Focus for 2027
The SEC's 2027 examination priorities extend across a broad range of risks and market participants, including:
- Retail investor protection, particularly around complex, higher-risk and illiquid products
- Private funds, private credit and complex investment strategies
- Broker-dealer financial responsibility, trading practices and supervision
- Cybersecurity and operational resilience
- Protection of customer information
- Third-party service provider risk
- Treasury clearing reforms, tokenization and evolving market infrastructure
- Oversight of self-regulatory organizations and other critical market participants
With digital assets and tokenization a continued concern across the regulatory landscape, read our white paper on digital asset and crypto compliance for more on managing the evolving compliance risks.
The priorities note that Division will also continue to prioritize examinations of investment advisers that have never been examined, with particular emphasis on recently registered advisers. Visit our RIA Compliance Checklist: SEC Requirements & Key Obligations in 2026 for more information.
MCO Helps Firms Prepare for SEC Examinations in 2027
The 2027 priorities reinforce a consistent theme across the SEC's examination program: compliance programs need to reflect the risks, activities and technology actually present across the business. For a global perspective on 2027, download the Global Compliance Outlook report for insights from 370 senior compliance leaders on the priorities, risks and technology investments shaping the year ahead.
That becomes more challenging as firms introduce new products, enter new markets, complete acquisitions and incorporate technologies such as SI into more workflows.
For compliance teams, visibility and evidence remain critical. Firms need to understand where risks and potential conflicts exist, apply appropriate policies and controls, monitor activity and maintain a defensible record of how compliance obligations have been managed.
MyComplianceOffice brings together the management of compliance obligations across employees, transactions, and third parties on a single platform, giving compliance teams greater visibility into risk and the audit trail needed to evidence their compliance program to examiners from the SEC and other regulators across the globe.
Ready to learn more? Request a demo today to see how MCO can help your firm manage compliance expectations from the SEC and other global regulators.
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