BSA/AML Reform in the 2021 NDAA Becomes Law

On January 1, 2021, the Senate voted to override President Trump’s veto of the National Defense Authorization Act (the “NDAA” or “Act”), which includes over 200 pages of significant reforms to the Bank Secrecy Act (“BSA”) and other anti-money laundering (“AML”) laws that have been working their way through Congress for several years.  The Senate’s vote follows the House’s override on December 28, 2020, and the Act is now law.

The Act puts in place the most comprehensive set of BSA/AML reforms since the USA PATRIOT Act of 2001, including:

  • new beneficial ownership reporting requirements;
  • whistleblower and penalty enhancements; and
  • provisions emphasizing the importance of risk-based approaches to AML program requirements, and that would require Treasury to periodically publish on national AML and CTF priorities.

Click here to read an updated version of Covington’s December 11, 2020, client alert summarizing seven things to know about the reforms.

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