By Ellen Zimiles, Alma Angotti, Salvatore LaScala
The AMLA is contained in Division F of the National Defense Authorization Act, which was signed into law on January 1, 2021.
The AMLA is intended to clarify and streamline certain anti-money laundering (AML) and Bank Secrecy Act (BSA) obligations and is intended to strengthen, modernize, and improve compliance programs by:
The AMLA is divided into the following five titles:
As noted below, certain provisions of the AMLA became effective on January 1, 2021, with other provisions becoming effective at later dates. Additionally, the AMLA commissions a number of regulatory studies and reports, the ultimate effects of which are currently unknown, but may result in issuance of guidance, new requirements, or amendments to existing requirements.