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.
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.