Debevoise Insight: The Federal Government’s Focus on Anti-Money Laundering Compliance Continues
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Key takeaways:
- In this Debevoise In Depth, we survey and summarize the most recent such developments and provide context about the federal government’s broader efforts to revise the AML compliance framework.
- Most importantly, on June 30, 2021, the Financial Crimes Enforcement Network (“FinCEN”) issued government-wide AML and countering the financing of terrorism priorities, as required by the Anti-Money Laundering Act of 2020 (“AML Act”).
- The AML Act also required FinCEN to draft a report assessing whether it should establish a process for issuing no-action letters, which it published on June 30, 2021. The report concludes that no-action letters would be “a useful complement” to FinCEN’s current processes.
- Finally, on June 30, 2021, the Federal Financial Institutions Examination Council published updates to four sections of its Bank Secrecy Act / Anti-Money Laundering Examination Manual.