The Anti-Money Laundering Act of 2020: How and When it Might Affect You

By Ellen Zimiles, Alma Angotti, Salvatore LaScala

Overview of the Anti-Money Laundering Act of 2020 (AMLA)

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:

overview AMLA

Titles in the Anti-Money Laundering Act of 2020

The AMLA is divided into the following five titles:

AMLA Timelines

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.

AMLA 2020 timelines

Financial institutions should consider how they will: (1) address new regulatory requirements; and (2) be proactive in terms of potential future changes based on the various provisions in the AMLA, such as the findings from conducting various studies and reports.

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