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AML and Bank Secrecy Act Compliance: Increased Enforcement and Customer Identification Requirements

Recording of a 90-minute CLE video webinar with Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Thursday, September 9, 2021

Recorded event now available

or call 1-800-926-7926

This CLE course will provide corporate counsel guidance on creating compliance with Anti-Money Laundering and Bank Secrecy Act obligations. The panel will address the increased enforcement of these statutes and the escalating fines and penalties imposed on companies for AML violations.


Federal regulators are increasing their scrutiny of companies' compliance with Anti-Money Laundering and Bank Secrecy Act obligations. It appears that 2021 is likely to be a record year for penalties.

The National Defense Authorization Act for 2021 was passed by Congress and included the Anti-Money Laundering Act of 2020 (AML Act). The AML Act includes provisions for the creation of a federal database of beneficial owners; expanded coverage of the Bank Secrecy Act of 1970 (BSA) to include areas such as dealers in antiquities and virtual currencies; made available additional tools for law enforcement; heightened penalties for violations; and enhanced the AML whistleblower law.

In light of this increased regulatory scrutiny, the Federal Reserve, FDIC, National Credit Union Administration, and Office of the Comptroller of the Currency issued a joint statement on Aug. 13, 2020, which guides companies on minimum requirements of an effective BSA/AML compliance program.

The agencies specified four pillars that make up an adequate BSA/AML compliance program: (1) a system of internal controls that assure ongoing compliance; (2) independent testing; (3) a designated individual or individuals responsible for monitoring BSA/AML compliance, and (4) training for appropriate personnel. They added that the compliance program also must include a customer identification program with risk-based procedures to ensure the institution has a reasonable basis for knowing the identity of its customers, donors, vendors, and others with whom the company has financial transactions.

Corporate counsel should be aware that it is not only banks and other financial institutions that have these obligations. The FBI reportedly issued a bulletin in May 2020, calling for greater scrutiny on private investment funds to determine if they are adequately complying with AML programs. Further, while FinCEN has stated that charities and nonprofit organizations are not viewed as high risk entities for money laundering, it also reminded them that they must still have adequate AML safeguards in place.

Listen as our panel discusses the landscape of AML compliance in 2021 with regulators and law enforcement using the new tools they have been given through the AML Act, assessing increased monetary penalties, and making concerted efforts to monitor AML compliance of non-banking entities.



  1. AML/BSA
    1. Prior history
    2. Current enforcement
    3. Recent violations and fines
  2. Joint statement from the administrative agencies
    1. Compliance program requirements


The panel will review these and other important topics:

  • What is the history of enforcement of AML/BSA?
  • What are recent penalties issued under AML/BSA, and what were the alleged violations?
  • What are the best practices for creating a compliance program under the administrative joint statement?


Maimin, Rachel
Rachel Maimin

Lowenstein Sandler

Ms. Maimin has extensive trial experience in federal criminal proceedings and a strong background in internal...  |  Read More

Rosensaft, Michael
Michael M. Rosensaft

Katten Muchin Rosenman

Mr. Rosensaft helps individual clients at what is often the greatest crisis of their lives — facing government...  |  Read More

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