The Anti-Money Laundering Act (AMLA) and the Corporate Transparency Act (CTA) of 2020 are the two most significant updates to the Bank Secrecy Act of 1970 (BSA) since the USA PATRIOT Act of 2001. Financial institutions and compliance professionals must understand their impact and prepare for the required transition.
The AMLA and the CTA cover a broad range of amendments to Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) laws. In the near term, they affect financial services (FS) institutions and beneficial ownership reporting requirements for many non-FS corporations and limited liability corporations (LLCs).
AML/CFT operating environments are also expected to change further over the next several years due to changes that could subsequently arise from congressionally mandated studies and reports in the AMLA from various Federal agencies, such as the Department of the Treasury (Treasury), Attorney General or the Comptroller General of the U.S., (e.g., Suspicious Activity Report (SAR) and Currency Transaction Report (CTR) reporting thresholds, sharing SARs of a U.S. financial institution with its overseas entities, etc.).
However, this report focuses on the more immediate effects of the two new laws on U.S. Covered Financial Institutions’ (USCFIs’) AML/CFT Programs and their operations and on reporting requirements of non-FS firms.