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The NDAA Act of 2021 and Its Implications on AML Reforms



On December 11th, 2020, the US Senate passed a bill to strengthen the anti-money laundering (AML) rules and ban anonymous shell companies.


reporting entities will be required to report their beneficial owners to FinCEN at the time of registration, or within two years of passage of the AML Act.

It encourages technological innovation for AML/CFT purposes, requiring FinCEN and federal functional regulators to appoint ‘innovation officers’ to reach out to FIs and other stakeholders with respect to new methods and

technologies that may assist in compliance, and ensuring that VASPs are brought under the purview of the BSA.

It promotes communication and information sharing between FinCEN and FIs and also between US FIs and their foreign branches and affiliates.

In case of repeat violations of the BSA, the bill allows for civil penalties that are double the maximum for a first violation, or three times the violator’s profit resulting from the violation.


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