The anti-money laundering (“AML”) regulatory landscape is quickly evolving, and there have been a number of noteworthy developments, which this Debevoise in Depth highlights:
- On April 1, 2021, the Financial Crimes Enforcement Network issued an Advance Notice of Proposed Rulemaking to solicit public comment regarding the new beneficial ownership reporting requirements established by the Corporate Transparency Act.
- On April 12, 2021, federal banking regulators released an interagency statement clarifying how the “Supervisory Guidance on Model Risk Management” may be a used in the context of Bank Secrecy Act (“BSA”) compliance and requested comment on the extent to which risk management principles discussed in the MRMG relate to models used by banks to comply with BSA and Office of Foreign Assets Control requirements.
- On March 29, 2021, the Securities and Exchange Commission’s Division of Examinations released a Risk Alert highlighting recent observations of common compliance issues among broker-dealers with respect to suspicious activity reporting.
- On February 25, 2021, the Federal Financial Institutions Examination Council updated its BSA/AML Examination Manual, including by adding a new section that makes clear the importance of ensuring that practices align with risk profiles and appetites.