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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.