The Anti-Money Laundering Act of 2020 is the biggest change to AML legislation in the US in a generation. Key elements include:
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Fincen to collect data on UBO’s (whereas EU saw UBO registers). The precise mechanism of implementation has been subject to many battles and is interesting in its perspectives.
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Changes the purpose of the BSA from simply collecting data.
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AML Program requirements changed
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Fincen duties expanded
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Bank Secrecy Act Penalties Expanded
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New Bank Secrecy Act Advisory Groups (BSAAG)
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Subcommittee on Innovation and Technology
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Subcommittee on Information Security & Confidentiality
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Federal agencies must consider how to streamline AML reporting
What does the AML Act 2020 tangibly change?
- Clarity on mechanisms to collect UBO data
- Obligations on SME’s to submit UBO data to Fincen. This is basically every company in the US. So a huge burden on all companies, which is new.