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New Year, New Laws – Congress Passes Major Anti-Money Laundering Act


On January 1, 2021, Congress passed the National Defense Authorization Act for Fiscal Year 2021, an omnibus bill that includes the Anti-Money Laundering Act of 2020 (“AMLA”). The AMLA bans the use of anonymous shell companies by requiring the disclosure of beneficial owners. However, that is not all the AMLA does. Rather, the AMLA’s changes are sweeping with the beneficial owner disclosure requirement being only one of six major updates.

With that in mind, this legal alert addresses the AMLA’s impact on reporting companies and entities with anti-money laundering responsibilities, especially financial institutions.

Corporate Transparency Act

A primary feature of the AMLA is the establishment of the Corporate Transparency Act (“CTA”). The CTA requires certain businesses to disclose beneficial ownership information to the Financial Crimes Enforcement Network (“FinCEN”), and with that information, FinCEN will maintain a nonpublic beneficial ownership database.


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