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ARTICLE · 06 JANUARY 2021

BSA/AML Reform Under The NDAA

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On January 1, 2020, Congress voted to override the president's veto of the National Defense Authorization Act for Fiscal Year 2021 (NDAA), enacting the most significant overhaul of the...

United StatesGovernment, Public Sector
Arnold & Porter Kaye Scholer LLP
Arnold & Porter Kaye Scholer LLP
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On January 1, 2020, Congress voted to override the president's veto of the National Defense Authorization Act for Fiscal Year 2021 (NDAA), enacting the most significant overhaul of the Bank Secrecy Act and related anti-money laundering laws since the USA PATRIOT Act of 2001. The NDAA substantially amends Title 31 and sets a busy regulatory agenda for the incoming administration's Treasury Department and the Financial Crimes Enforcement Network (FinCEN).

A blackline comparison reflecting all of the substantive amendments to Title 31 is available here.

Several notable amendments include:

  • Beneficial Ownership Registry. By January 1, 2022, the Treasury Secretary is required to issue regulations requiring corporate entities (generally and subject to exceptions, any corporation, LLC, or other similar entity with 20 or fewer employees and annual gross income of $5 million or less) to report beneficial ownership information to FinCEN, which will be maintained by

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