The Anti-Money Laundering Act of 2020 is the biggest change to AML legislation in the US in a generation. Key elements include:

1. 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.

2. Changes the purpose of the BSA from simply collecting data.

3. AML Program requirements changed

4. Fincen duties expanded

5. Bank Secrecy Act Penalties Expanded

6. New Bank Secrecy Act Advisory Groups (BSAAG)

   • Subcommittee on Innovation and Technology

   • Subcommittee on Information Security & Confidentiality

7. 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.