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Enacted by Congress on January 1, 2021 under the National Defense Authorization Act for Fiscal Year 2021 (“NDAA”), the Anti-Money Laundering Act of 2020 (“AMLA”) seeks to overhaul the country’s anti-money laundering/countering the financing of terrorism (“AML/CFT”) regime.
While there are many interesting aspects of this legislation that will likely be debated and discussed for months to come, this note focuses on the some of the likely and more significant compliance and operational impacts to financial institutions and their customers. Although some of these provisions will not be implemented for over a year, the plan to comply with these new requirements will likely need to begin soon so that appropriate procedure, process and system changes can be made, tested and validated.
