The Anti-Money Laundering Act (AMLA) of 2020
Last updated: July 15, 2025
The Anti-Money Laundering Act (AMLA) of 2020 represents a significant overhaul of the U.S. anti-money laundering (AML) regime, building upon and modernizing the existing framework established by the Bank Secrecy Act (BSA). Enacted as part of the National Defense Authorization Act, the AMLA aims to strengthen, streamline, and modernize AML and counter-terrorism financing (CFT) laws12.
Key provisions of the AMLA include:
Beneficial Ownership Registry: The Act mandates the creation of a centralized beneficial ownership registry maintained by the Financial Crimes Enforcement Network (FinCEN). This registry aims to enhance transparency and combat the use of shell companies for illicit purposes3.
Expanded BSA/AML Scope: The AMLA broadens the definition of "financial institution" to include businesses dealing with virtual currencies, thus expanding regulatory oversight to the cryptocurrency sector1.
Whistleblower Program: The Act establishes a robust whistleblower program, offering increased protections and incentives for individuals who report BSA violations4.
Enhanced Penalties: The AMLA significantly increases civil and criminal penalties for BSA/AML violations, including the possibility of clawing back bonuses from executives of repeat offenders1.
Focus on Innovation: The Act promotes the adoption of new technologies in AML efforts, encouraging financial institutions to implement innovative approaches to compliance2.
Information Sharing: The AMLA enhances information sharing capabilities between financial institutions, regulators, and law enforcement agencies1.
AML/CFT Priorities: The Act requires FinCEN to establish and periodically update national AML and CFT priorities, which financial institutions must incorporate into their compliance programs5.
Expanded Subpoena Powers: The AMLA grants the Department of Justice and Treasury expanded subpoena powers over foreign banks maintaining correspondent accounts in the U.S.1.
The AMLA represents a significant shift towards a more risk-based, technology-driven approach to AML compliance. It addresses long-standing issues in the AML framework, such as the lack of beneficial ownership information, while also preparing the financial system to combat emerging threats in areas like cryptocurrency32.
Implementation of the AMLA is an ongoing process, with various provisions being rolled out over time. Financial institutions are required to adapt their compliance programs to meet these new requirements, which may involve significant operational changes and technology investments2.
By modernizing the AML framework, the AMLA aims to enhance the effectiveness of financial crime prevention efforts while reducing unnecessary regulatory burdens on financial institutions. This comprehensive reform is expected to have far-reaching impacts on the financial industry and the fight against money laundering and terrorist financing12.