Welcome to the AMLA Coffee Break, a collaborative web series with Guidehouse and Pillsbury Winthrop Shaw Pittman, where we discuss the various topics in the Anti-Money Laundering Act (AMLA) of 2020. The AMLA is the first major overhaul of the U.S. AML regime since the 2001 USA PATRIOT Act, and is designed to strengthen national security, protect the financial system, and simplify compliance obligations.
This episode is focused on the provision dealing with the subpoenas of foreign banks, so settle in and pour yourself a cup of coffee as we kickoff our AMLA Coffee Break Web Series.
The real nuclear penalty option on this is that the DOJ and Treasury can order a US bank to terminate the correspondent relationship within 10 business days. I have helped banks wind down correspondent relationships voluntarily and it is difficult to do in 6 months, let alone 10 days.
Partner & Global Legislative and Regulatory Risk Leader