The new Anti-Money Laundering Act of 2020 (AMLA or the Act) established the most comprehensive set of reforms to American anti-money laundering (AML) law since the passage of the Patriot Act in 2001. The AMLA—which was quietly passed in the massive 2021 National Defense Authorization Act—strengthened existing government authority to regulate and police money laundering. Specifically, the Act expands Justice and Treasury Department power to investigate and punish both anti-money laundering and Bank Secrecy Act (BSA) violations. In doing so, the AMLA’s reforms present particularly significant implications for financial institutions and their AML compliance programs.

Enhanced Penalties for BSA/AML Violations. The AMLA enhances penalties for BSA and anti-money laundering violations. These provisions will provide prosecutors with increased leverage in enforcing AML prohibitions and motivate them to focus on actively pursuing criminal activity in this space.