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FinCEN Director Describes Implementation Efforts for 2020 AML Act's picture
Commentary by Christian Larson

FinCEN Director Kenneth Blanco outlined the bureau’s implementation efforts since the enactment of the Anti-Money Laundering Act of 2020 (the "AML Act"). Mr. Blanco asserted that the AML Act is the most expansive addition to the United States' AML regime since the USA PATRIOT Act of 2001.

In his address before the Florida International Bankers Association AML Conference, Mr. Blanco noted recent agency guidance (see previous coverage) that called upon financial institutions to file suspicious activity reports ("SARs") about illicit activities involving antiquities and works of art. Mr. Blanco emphasized that the information provided in such SARs will inform the agency's rulemaking efforts to bolster AML requirements for antiquities dealers.

Mr. Blanco also stated that FinCEN intends to issue an Advance Notice of Proposed Rulemaking (or "ANPRM") in connection with the beneficial ownership reporting requirements under the Corporate Transparency Act, which is part of the AML Act. Mr. Blanco stated that the agency will direct efforts toward ensuring that the beneficial ownership information that is collected, stored and protected by the agency can aid in the creation of a "highly useful" IT database system for FinCEN's stakeholders. Currently, FinCEN is in the process of creating use and confidentiality protocols that will govern access to the beneficial ownership database.


The AML Act (also called AMLA 2020 - Cadwalader’s overview is available here) requires Treasury to issue a slew of implementing regulations over the next three years. Here, Director Blanco is calling upon industry to provide comments on draft regulations as they are proposed. Director Blanco provided no indication of when the ANPRM in connection with the Corporate Transparency Act might be issued.

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