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BSA/AML Reform Resource Center

On January 1, 2021, Congress voted to override the president's veto of the National Defense Authorization Act for Fiscal Year 2021, enacting the Anti-Money Laundering Act of 2020 (AML Act) and the most significant overhaul of the Bank Secrecy Act and related anti-money laundering laws since the USA PATRIOT Act of 2001. The AML Act substantially amended Title 31 and set a demanding regulatory agenda for the Treasury Department and the Financial Crimes Enforcement Network (FinCEN), which the government is busy implementing.

On this page, Arnold & Porter tracks the legal developments and rulemaking resulting from the AML Act and provides our insights on the impact on the financial services industry.

Overview of BSA/AML reform under the AML Act

National AML/CFT Priorities (Sec. 6101)

Strengthening FinCEN and Expanding Reporting Authorities (Sec. 6102)

Application of AML Requirements to Arts and Antiquities (Sec. 6110)

Sharing of Threat Pattern and Trend Information (Sec. 6206)

FinCEN Pilot Program on SAR Sharing (Sec. 6212)

Review of Regulations and Guidance (Sec. 6216)

Assessment of FinCEN No-Action Letter Process (Sec. 6305)

Expansion of DOJ and Treasury Authority to Reach Account Records Maintained by Foreign Banks with US Correspondent Accounts (Sec. 6308)

Beneficial Ownership and the Corporate Transparency Act (Sec. 6402–6403)

AML Whistleblower Protection and Incentives (Sec. 6314)

Resources

Meet the Team

Blackline Comparison of Substantive Amendments to Title 31

Statement of FinCEN Acting Director Das before the House Committee on Financial Services

Text of AML Act of 2020

Treasury Department Agency Rule List and Regulatory Agenda

Latest advisories covering trends in Financial Services, Securities Enforcement & Litigation and White Collar Defense & Investigations

Perspectives

What AML Bill Could Mean for Firms, Funds and FinCEN
Law360
Update: Congress Seeks to Impose Some AML Obligations on CPAs, Law Firms, and Others
Advisory
Congress Seeks to Impose AML Obligations on CPAs, Investment Advisors, Law Firms, and Others
Advisory
FinCEN Requests Feedback on No-Action Letter Process
Advisory
Treasury Department Focuses on Emerging Digital Art Market and NFTs
Enforcement Edge: Shining Light on Government Enforcement
What to Know About FinCEN’s Proposed Pilot Program on SAR Sharing
Advisory
FinCEN Issues ANPRM to Address Money Laundering Vulnerabilities in the Real Estate Sector
Advisory
What to Know About FinCEN's Proposed Rule to Implement the Beneficial Ownership Information Reporting Requirements of the Corporate Transparency Act
Advisory
FinCEN Takes First Step in Antiquities Rulemaking
Advisory
Key Considerations for Financial Institutions Subject to the New AML Whistleblower Law (Video)
Advisory
FinCEN Issues First ANPRM Seeking Comment on the Implementation of the New Beneficial Ownership Reporting Provisions of the Corporate Transparency Act
Advisory
Recently Enacted NDAA Expands the Bank Secrecy Act To Regulate the Antiquities Trade (and Possibly Eventually the Art Market)
Enforcement Edge: Shining Light on Government Enforcement
NDAA Significantly Expands DOJ and Treasury Authority to Reach Account Records Maintained by Foreign Banks with US Correspondent Accounts
Advisory
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