The Anti-Money Laundering Act of 2020 (AMLA) is the most significant AML/CFT legislation in years. The AMLA is designed to modernize the existing AML/CFT framework to make it more risk-based and focused on matters of highest priority to law enforcement, while promoting information-sharing and the use of technological innovation in AML/CFT compliance. However, there is little in the AMLA that is self-effectuating, and the statute requires the U.S. Treasury Department/FinCEN to issue regulations to implement the statute. To date, there have been some significant developments, mainly with respect to implementation of the Corporate Transparency Act provisions in the statute.
Some of the key actions taken to date include the following:
- In June 2021, FinCEN issued its first list of National AML/CFT Priorities, pursuant to AMLA.
- In December 2021 FinCEN issued an RFI to seek feedback on the modernization of the existing AML/CFT framework under the Bank Secrecy Act (BSA).
- On September 30, 2022, FinCEN published a final rule regarding requirements for certain legal entities to submit their beneficial ownership and company applicant information (BOI) to the agency and, on December 15, FinCEN issued a proposal governing access to and safeguarding of the BOI registry.
During the webinar, we discuss the AMLA and other important developments concerning AML/CFT reform. For this discussion, Kharon Chief Client Officer and former Acting Assistant Secretary of Treasury Howard Mendelsohn is joined by Dan Stipano, a Partner at Davis Polk and a recognized authority on BSA/AML issue who spent 30 years at the Office of the Comptroller of the Currency.
Chief Client Officer