New U.S. Law’s Impacts on Non-U.S. Financial Institutions

February 18, 2021 - Policy Alerts

The U.S. Anti-Money Laundering Act of 2020 (AML Act) became law on January 1 when the United States Congress passed the broader National Defense Authorization Act for 2021 over a presidential veto.

Although it is a U.S. law, it is critical that non-U.S. financial institutions, particularly those that rely on U.S. correspondent banking relationships or transact in U.S. dollars, understand how the AML Act will impact them—both directly and by shaping U.S. actors’ expectations for their foreign partners. In general, the AML Act aims to improve coordination and information sharing; to modernize the U.S. anti-money laundering/combating the financing of terrorism (AML/CFT) regime; to encourage adoption of new compliance technologies; to reinforce the risk-based approach; and to create beneficial ownership reporting requirements to prevent illicit activity and protect U.S. national security.

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