AMLA 2020 Summary Grid - Updated as of July 1, 2021 - Guidehouse
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AMLA 2020 Summary Grid
Updated as of July 1, 2021
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Contents
Anti-Money Laundering Act of 2020 (Division F, sec 6001-6511)
Title LXI—Strengthening Treasury
Title LXII—Modernizing
Financial Intelligence, Anti-Money
Division F—Anti-Money Laundering the AML and CTF
Laundering, and Countering the
Reporting System
Financing of Terrorism Programs
Title LXIII—Improving Title LIV—Establishing Beneficial
Title LXV—
AML and CTF Communication, Ownership Information Reporting
Miscellaneous
Oversight and Processes Requirements
Table of Contents—Sections
Table of Contents—Sections
Title LXI—Strengthening Treasury Financial Intelligence, Anti-Money Laundering, and Title LXIII—Improving Anti-money Laundering and Countering the Financing of Terrorism
Countering the Financing of Terrorism Programs Communication, Oversight, and Processes
• Sec. 6101. Establishment of national exam and supervision priorities. • Sec. 6301. Improved interagency coordination and consultation.
• Sec. 6102. Strengthening FinCEN. Sec. • Sec. 6302. Subcommittee on Information Security and Confidentiality.
• Sec. 6103. FinCEN Exchange. • Sec. 6303. Establishment of Bank Secrecy Act Information Security Officers.
• Sec. 6104. Interagency anti-money laundering and countering the financing of terrorism • Sec. 6304. FinCEN analytical hub.
personnel rotation program. • Sec. 6305. Assessment of Bank Secrecy Act no-action letters.
• Sec. 6105. Terrorism and financial intelligence special hiring authority. • Sec. 6306. Cooperation with law enforcement.
• Sec. 6106. Treasury Attache´ program. • Sec. 6307. Training for examiners on anti-money laundering and countering the financing of
• Sec. 6107. Establishment of FinCEN Domestic Liaisons. terrorism.
• Sec. 6108. Foreign Financial Intelligence Unit Liaisons. • Sec. 6308. Obtaining foreign bank records from banks with United States correspondent
• Sec. 6109. Protection of information exchanged with foreign law enforcement and financial accounts.
intelligence units. • Sec. 6309. Additional damages for repeat Bank Secrecy Act violators.
• Sec. 6110. Bank Secrecy Act application to dealers in antiquities and assessment of Bank • Sec. 6310. Certain violators barred from serving on boards of United States financial
Secrecy Act application to dealers in arts. institutions.
• Sec. 6111. Increasing technical assistance for international cooperation. • Sec. 6311. Department of Justice report on deferred and non-prosecution agreements.
• Sec. 6112. International coordination. • Sec. 6312. Return of profits and bonuses.
• Sec. 6313. Prohibition on concealment of the source of assets in monetary transactions.
Title LXII—Modernizing the AML and CTF Reporting System • Sec. 6314. Updating whistleblower incentives and protection.
• Sec. 6201. Annual reporting requirements.
• Sec. 6202. Additional considerations for suspicious activity reporting requirements. Title LXIV—Establishing Beneficial Ownership Information Reporting Requirements
• Sec. 6203. Law enforcement feedback on suspicious activity reports. • Sec. 6401. Short title.
• Sec. 6204. Streamlining requirements for currency transaction reports and suspicious • Sec. 6402. Sense of Congress.
activity reports. • Sec. 6403. Beneficial ownership information reporting requirements.
• Sec. 6205. Currency transaction reports and suspicious activity reports thresholds review.
• Sec. 6206. Sharing of threat pattern and trend information. Title LXV—Miscellaneous
• Sec. 6207. Subcommittee on Innovation and Technology. • Sec. 6501. Investigations and prosecution of offenses for violations of the securities laws.
• Sec. 6208. Establishment of Bank Secrecy Act Innovation Officers. • Sec. 6502. GAO and Treasury studies on beneficial ownership information reporting
• Sec. 6209. Testing methods rulemaking. requirements.
• Sec. 6210. Financial technology assessment. • Sec. 6503. GAO study on feedback loops.
• Sec. 6211. Financial crimes tech symposium. • Sec. 6504. GAO CTR study and report.
• Sec. 6212. Pilot program on sharing of information related to suspicious activity reports • Sec. 6505. GAO studies on trafficking.
within a financial group. • Sec. 6506. Treasury study and strategy on trade-based money laundering.
• Sec. 6213. Sharing of compliance resources. • Sec. 6507. Treasury study and strategy on money laundering by the People’s Republic of
• Sec. 6214. Encouraging information sharing and public-private partnerships. China.
• Sec. 6215. Financial services de-risking. • Sec. 6508. Treasury and Justice study on the efforts of authoritarian regimes to exploit the
• Sec. 6216. Review of regulations and guidance. financial system of the United States.
• Sec. 6509. Authorization of appropriations.
• Sec. 6510. Discretionary surplus funds.
• Sec. 6511. Severability.
Division F Title LXI Title LXII Title LXIII Title LIV Title LXV
Division F—Anti-Money Laundering
National Relevant Date(s)
Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Division F—Anti-Money Laundering
Short Title 6001 This title may be referred Signed into law on It is important to
to as the Anti-Money January 1, 2021 note that while
Laundering Act of 2020 the AMLA was
(AMLA). signed into law on
January 1, 2021, not
all of its provisions
become effective
or operational on
that date.
Certain provisions
become effective
or operational
only upon the
effective date of
rules developed
and drafted
by regulatory
agencies.
Sections 6001-6002 Table of Contents—Sections
Division F Title LXI Title LXII Title LXIII Title LIV Title LXV
National Relevant Date(s)
Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Division F—Anti-Money Laundering
Short Title 6001 This title may be referred Signed into law on Certain provisions
to as the Anti-Money January 1, 2021 commission
Laundering Act of 2020 regulatory
(AMLA). agencies to
conduct a study
and provide a
report to Congress
that may result in
the issuance of
guidance or new
rules.
Sections 6001-6002 Table of Contents—SectionsDivision F Title LXI Title LXII Title LXIII Title LIV Title LXV
National Relevant Date(s)
Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Division F—Anti-Money Laundering
Purposes 6002 Purposes of the AMLA Signed into law on See Section 6101
are to: January 1, 2021
1. Improve agency
coordination and
information sharing.
2. Adapt laws to new and
emerging threats.
3. Encourage
technological
innovation.
4. Reinforce the nature of
“risk-based” programs.
5. Establish beneficial
ownership
requirements
designed to increase
transparency, prevent
use of shell companies,
and assist national
security and law
enforcement efforts.
6. Establish a beneficial
ownership database.
Sections 6001-6002 Table of Contents—SectionsDivision F Title LXI Title LXII Title LXIII Title LIV Title LXV
Title LXI—Strengthening Treasury Financial Intelligence, Anti-Money Laundering, and
Countering the Financing of Terrorism Programs
National Relevant Date(s)
Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Title LXI—Strengthening Treasury Financial Intelligence, Anti-Money Laundering, and Countering the Financing of Terrorism Programs
Establishment of 6101 Requires the secretary June 30, 2021 Secretary of the April 12, 2021 - The Financial Crimes Enforcement Network
national of the Treasury to publish Treasury must (FinCEN) announced it would host a special monthly virtual FinCEN
exam and a report outlining Anti- publish the first Innovation Hours Program on June 10, 2021, focusing on the
supervision Money Laundering/ report by June 30, important role of underserved groups in developing technology to
priorities Combating the Financing 2021, and provide fight illicit financial activity and protect the nation’s security.
of Terrorism (AML/ an updated report
CFT) policy priorities at least once every Note: FinCEN has not yet released any further information on the
and requires that four years. June 10, 2021 program.
exams evaluate a June 30, 2021 - FinCEN issued its first government-wide priorities
financial institution’s (FI for AML/CTF. Priorities include:
) incorporation of the
identified priorities into 1. Corruption;
their risk-based AML/CFT 2. Cybercrime, including relevant cybersecurity and virtual
programs. currency considerations;
3. Foreign and domestic terrorist financing;
4. Fraud;
5. Transnational criminal organization activity;
6. Drug trafficking organization activity;
7. Human trafficking and human smuggling; and
8. Proliferation financing.
Sections 6101-6112 Table of Contents—SectionsDivision F Title LXI Title LXII Title LXIII Title LIV Title LXV
National Relevant Date(s)
Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Title LXI—Strengthening Treasury Financial Intelligence, Anti-Money Laundering, and Countering the Financing of Terrorism Programs
Establishment of 6101 Requires the secretary June 30, 2021 Secretary of the FinCEN will issue regulations that will specify how financial
national of the Treasury to publish Treasury must institutions should incorporate these priorities into their risk-
exam and a report outlining Anti- publish the first based AML programs at a later date. However, FinCEN issued
supervision Money Laundering/ report by June 30, two statements providing guidance to financial institutions on
priorities Combating the Financing 2021, and provide actions they should take prior to the issuing regulations. While
of Terrorism (AML/ an updated report banks and covered non-bank financial institutions (NBFIs) are
CFT) policy priorities at least once every not required to incorporate the AML/CFT priorities into their
and requires that four years. risk-based AML programs until the effective date of the final
exams evaluate a regulations, in preparation for any new requirements arising out
financial institution’s (FI of the final regulations, banks should begin to consider how they
) incorporation of the will incorporate the AML/CFT priorities into their risk-based Bank
identified priorities into Secrecy Act (BSA) compliance programs, e.g., by assessing the
their risk-based AML/CFT potential related risks associated with the products and services
programs. they offer, the customers they serve, and the geographic areas in
which they operate.
Establishment of 6101 Requires FinCEN to December 27, 2021 FinCEN
national provide regulations to must provide
exam and carry out publication of corresponding
supervision the updated AML/CTF regulations within
priorities priorities. 180 days of the
report published
by the secretary of
the Treasury.
Sections 6101-6112 Table of Contents—SectionsDivision F Title LXI Title LXII Title LXIII Title LIV Title LXV
National Relevant Date(s)
Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Title LXI—Strengthening Treasury Financial Intelligence, Anti-Money Laundering, and Countering the Financing of Terrorism Programs
Strengthening 6102 Removes the word January 1, 2021 Effective January
FinCEN “international” to broaden 1, 2021
the term terrorism to
account for domestic and
international.
Strengthening 6102 Revises the definition January 1, 2021 Effective January
FinCEN of “money transmitting 1, 2021
business” to include
entities that provide
services involving “value
that substitutes for
currency” – a category
that includes stored value
and virtual currency
instruments:
1. Changed ‘‘funds,’’ with
‘‘currency, funds, or
value that substitutes
for currency.”
2. Changed ‘‘currency
or funds denominated
in the currency of any
country’’ to ‘‘currency,
funds, or value that
substitutes for
currency.’’
Sections 6101-6112 Table of Contents—SectionsDivision F Title LXI Title LXII Title LXIII Title LIV Title LXV
National Relevant Date(s)
Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Title LXI—Strengthening Treasury Financial Intelligence, Anti-Money Laundering, and Countering the Financing of Terrorism Programs
Strengthening 6102 3. Changed ‘‘currency or January 1, 2021 Effective January
FinCEN funds, or the value of 1, 2021
the currency or funds,’’
to ‘‘currency, funds, or
value that substitutes
for currency.’’
FinCEN 6103 Establishes the FinCEN January 1, 2021 Effective January March 23, 2021 - FinCEN Exchange brought public and private
Exchange exchange to promote 1, 2021 stakeholders together to discuss BSA/Suspicious Activity Report
voluntary public-private (SAR) statistics.
information sharing.
FinCEN 6103 FinCEN is required to TBD FinCEN must
Exchange promulgate regulations promulgate
that establish procedures regulations as
for sharing information appropriate.
pursuant to the
establishment of the
FinCEN Exchange.
Sections 6101-6112 Table of Contents—SectionsDivision F Title LXI Title LXII Title LXIII Title LIV Title LXV
National Relevant Date(s)
Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Title LXI—Strengthening Treasury Financial Intelligence, Anti-Money Laundering, and Countering the Financing of Terrorism Programs
FinCEN 6103 Requires that Treasury January 1, 2022 Secretary of the
Exchange publish a report regarding Treasury must
the effectiveness of the publish the report
FinCEN exchange and by January 1, 2022,
recommendations to and provide an
strengthen FinCEN. updated report
once every two
years thereafter for
the next five years.
Interagency 6104 Establishes a personnel January 1, 2021 Effective January
anti-money rotation program between 1, 2021
laundering and the federal functional
countering regulators and the
the financing Department of Justice
of terrorism (DoJ), the FBI, Department
personnel of Homeland Security
rotation (DHS), Department
program of Defense (DoD),
and other agencies
to enhance efficiency
and effectiveness in
combatting AML/CTF.
Sections 6101-6112 Table of Contents—SectionsDivision F Title LXI Title LXII Title LXIII Title LIV Title LXV
National Relevant Date(s)
Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Title LXI—Strengthening Treasury Financial Intelligence, Anti-Money Laundering, and Countering the Financing of Terrorism Programs
Terrorism 6105 Allows the secretary of January 1, 2021 Effective January
and financial the Treasury to appoint 1, 2021
intelligence candidates directly into
special hiring positions in FinCEN and
authority the Office of Terrorism
and Financial Intelligence
without going through the
usual federal government
hiring processes.
Terrorism 6105 Requires the secretary January 1, 2022 Secretary of the
and financial of the Treasury to submit Treasury must
intelligence a report that includes submit a report by
special hiring number of new employees January 1, 2022.
authority hired, along with their titles Secretary of the
and pay grades. Treasury must
provide an updated
report once
every two years
thereafter for the
next five years.
Treasury 6106 Facilitates hiring and January 1, 2021 Effective January
attaché program use of attachés abroad 1, 2021
to enhance reach and
effectiveness of US AML/
CTF efforts.
Sections 6101-6112 Table of Contents—SectionsDivision F Title LXI Title LXII Title LXIII Title LIV Title LXV
National Relevant Date(s)
Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Title LXI—Strengthening Treasury Financial Intelligence, Anti-Money Laundering, and Countering the Financing of Terrorism Programs
Establishment 6107 Establishes a FinCEN January 1, 2021 Effective January
of FinCEN Office of Domestic 1, 2021
Domestic Liaison, headed by the
Liaisons chief domestic liaison, to
communicate with FIs and
non-financial institutions
and federal and state
regulators to:
1. Promote consistency of
supervisory guidance.
2. Communicate
regarding information
sharing.
3. Establish confidentiality
of communications.
4. Propose changes
to regulations and
guidance.
Establishment 6107 Requires director of January 1, 2022 Director of FinCEN
of FinCEN FinCEN to submit a must submit a
Domestic report to Congress on the report by January 1,
Liaisons objectives of the Office 2022, and provide
of the Domestic Liaison an updated report
for the following fiscal once every two
year, and activities of the years thereafter for
immediate prior year. the next five years.
Sections 6101-6112 Table of Contents—SectionsDivision F Title LXI Title LXII Title LXIII Title LIV Title LXV
National Relevant Date(s)
Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Title LXI—Strengthening Treasury Financial Intelligence, Anti-Money Laundering, and Countering the Financing of Terrorism Programs
Foreign financial 6108 Facilitates hiring of at least January 1, 2021 Effective January
intelligence unit six foreign FIU liaisons 1, 2021
liaisons to Egmont and FATF to
promote international
coordination and
cooperation.
Protection of 6109 Establishes that Freedom January 1, 2021 Effective January
information of Information Act 1, 2021
exchanged requests do not apply
with foreign law to communication
enforcement between Department
and financial of Treasury and foreign
intelligence law enforcement, foreign
units financial intelligence unit,
or foreign AML and CTF
authority. Such information
may only be provided to
the US Congress or by an
order of a US court.
Sections 6101-6112 Table of Contents—SectionsDivision F Title LXI Title LXII Title LXIII Title LIV Title LXV
National Relevant Date(s)
Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Title LXI—Strengthening Treasury Financial Intelligence, Anti-Money Laundering, and Countering the Financing of Terrorism Programs
Expands BSA 6110 Amends BSA to include December 27, 2021 Secretary of March 9, 2021 - FinCEN issued a notice on how to use the SAR form
Application persons engaged in Treasury required for arts and antiquities-related filings.
to antiquities antiquities trading, to issue proposed
dealers advisory, consulting, or any rules by December
other related businesses 27, 2021. BSA
engaged in solicitation amendment takes
or sale and requires the effect once the
secretary of the Treasury final rules are
to issue proposed rules to issued.
carry out the amendments
no later than 360 days
after the Act is enacted.
Study of BSA 6110 Requires secretary December 27, 2021 Secretary of
application to art of the Treasury to Treasury required
dealers conduct a study on the to conduct
facilitation of money the study and
laundering and financing submit a report
of terrorism through by December 27,
art trade and submit a 2021.
report of the findings and
determinations no later
than 360 days after the Act
is enacted.
Sections 6101-6112 Table of Contents—SectionsDivision F Title LXI Title LXII Title LXIII Title LIV Title LXV
National Relevant Date(s)
Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Title LXI—Strengthening Treasury Financial Intelligence, Anti-Money Laundering, and Countering the Financing of Terrorism Programs
Increasing 6111 Authorizes appropriation of January 1, 2021 Effective January
technical $60 million each year from 1, 2021
assistance for 2020 to 2024 to provide
international technical assistance to
cooperation foreign countries and
financial institutions
in foreign countries to
promote compliance with
international standards
and best practices in
establishing an effective
AML and CTF programs.
Increasing 6111 Requires secretary of January 1, 2022 Secretary of the
technical the Treasury provide Treasury must
assistance for Congress with reports on submit a report by
international the assistance provided, January 1, 2022.
cooperation to whom assistance Secretary of the
was provided, and who Treasury must
provided the assistance provide an updated
(other than government report once
staff). every two years
thereafter for the
next five years.
Sections 6101-6112 Table of Contents—SectionsDivision F Title LXI Title LXII Title LXIII Title LIV Title LXV
National Relevant Date(s)
Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Title LXI—Strengthening Treasury Financial Intelligence, Anti-Money Laundering, and Countering the Financing of Terrorism Programs
International 6112 Requires secretary of the January 1, 2021 Effective January February 25, 2021 - FATF finalized a non-public report on terrorist
coordination Treasury work with foreign 1, 2021 financing and agreed to seek public comment on updated guidance
counterparts, including documents on virtual assets and proliferation financing.
FATF, IMF, World Bank,
Egmont Group, OECD, March 11, 2021 - FATF published an updated list of AML deficient
Basel, and UN to promote countries.
stronger AML frameworks
and enforcement of AML
laws.
Sections 6101-6112 Table of Contents—SectionsDivision F Title LXI Title LXII Title LXIII Title LIV Title LXV
Title LXII—Modernizing the AML and CTF Reporting System
National Relevant Date(s)
Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Title LXII—Modernizing the AML and CTF Reporting System
Annual reporting 6201 Requires attorney general January 1, 2022 Attorney general
requirements (AG) in consultation with must submit an
other agencies provide an annual report for
annual report to secretary a period of five
of the Treasury that: years, with first
report issued by
1. Evaluates the January 1, 2022.
usefulness of BSA Attorney general
reporting to law must provide an
enforcement. updated report
2. Addresses money once every five
laundering and terrorist years thereafter.
financing trends
associated with BSA
reporting.
The reports shall be used
to assess the usefulness
of BSA reporting and
enhance communication
between the government
and financial institutions.
Sections 6201-6216 Table of Contents—SectionsDivision F Title LXI Title LXII Title LXIII Title LIV Title LXV
National Relevant Date(s)
Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Title LXII—Modernizing the AML and CTF Reporting System
Additional 6202 Requires that regulators January 1, 2021 Effective January
considerations consider Treasury 1, 2021
for SAR priorities, BSA purposes
reporting and means of reporting,
requirements including burdens
associated with filing, when
imposing and considering
revisions to SAR reporting
requirements.
Additional 6202 Requires that SAR filings January 1, 2021 Effective January
considerations by FIs be guided by their 1, 2021
for SAR compliance program,
reporting including their risk
requirements assessment processes.
(Compliance
Program
Requirements)
Sections 6201-6216 Table of Contents—SectionsDivision F Title LXI Title LXII Title LXIII Title LIV Title LXV
National Relevant Date(s)
Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Title LXII—Modernizing the AML and CTF Reporting System
Additional 6202 Requires the secretary TBD No official date is
considerations of the Treasury, acting provided for when
for SAR through director of the streamlined
reporting FinCEN to establish process must be
requirements streamlined (automated) established.
(Streamlined processes to file “non-
Data and Real- complex” reports in order
Time Reporting) to reduce burdens on FIs
while not compromising
the usefulness of SAR
information. [as an aside
“non-complex” is not
defined].
Law 6203 Requires FinCEN, to the Periodic FinCEN must
enforcement extent practicable, to periodically solicit
feedback on solicit feedback from BSA feedback.
SARs officers at FIs to review
SARs and discuss trends
observed by FinCEN
and that FinCEN share
feedback with functional
regulators, state bank
supervisors, and credit
union supervisors.
Sections 6201-6216 Table of Contents—SectionsDivision F Title LXI Title LXII Title LXIII Title LIV Title LXV
National Relevant Date(s)
Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Title LXII—Modernizing the AML and CTF Reporting System
Law 6203 Requires FinCEN, to the Periodic FinCEN must
enforcement extent practicable, to periodically
feedback on periodically disclose to FIs’ disclose SAR
SARs (Sharing summary SAR information information.
with FIs) that proved useful to law
enforcement.
Streamlining 6204 Requires that the January 1, 2022 Report must
requirements for secretary of the Treasury, include findings as
CTRs and SARS in consultation with well as proposed
regulators and other rules.
relevant stakeholders,
conduct a formal review of
SAR and CTR requirement
and deliver a report
that includes proposed
rules (as appropriate) to
reduce burdens on FIs
and improve reports. The
review will include:
1. Whether the
circumstances to file a
continuing SAR, and/or
the processes followed
to file a continuing SAR
should be streamlined
or adjusted.
Whether different
thresholds should apply
to different categories
of activities.
Sections 6201-6216 Table of Contents—SectionsDivision F Title LXI Title LXII Title LXIII Title LIV Title LXV
National Relevant Date(s)
Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Title LXII—Modernizing the AML and CTF Reporting System
Streamlining 6204 2. Whether different January 1, 2022 Report must
requirements for thresholds should apply include findings as
CTRs and SARS to different categories well as proposed
of activities. rules.
3. Whether the number or
nature of the SAR and
CTR form fields should
be adjusted.
4. The categories, types,
and characteristics of
SARs and CTRs that
are of the greatest value
to law enforcement
and national security
agencies.
5. The increase of
exemption provisions
to reduce CTRs that
aren’t useful to law
enforcement.
Sections 6201-6216 Table of Contents—SectionsDivision F Title LXI Title LXII Title LXIII Title LIV Title LXV
National Relevant Date(s)
Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Title LXII—Modernizing the AML and CTF Reporting System
Streamlining 6204 6. The most appropriate January 1, 2022 Report must
requirements for ways to promote include findings as
CTRs and SARS financial inclusion well as proposed
and consequences rules.
of de-risking entire
categories of
relationships, including
charities, embassy
accounts, and money
service businesses
and certain groups of
correspondent banks
without conducting a
proper assessment
of the specific risk of
each individual member
of these populations.
The current reporting
requirements under
BSA, and regulations
and guidance
implementing the BSA.
7. The appropriate
manner in which to
ensure the security
and confidentiality of
personal information.
Sections 6201-6216 Table of Contents—SectionsDivision F Title LXI Title LXII Title LXIII Title LIV Title LXV
National Relevant Date(s)
Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Title LXII—Modernizing the AML and CTF Reporting System
Streamlining 6204 8. How to improve the January 1, 2022 Report must
requirements for cross-referencing of include findings as
CTRs and SARS individuals or entities well as proposed
operating at multiple rules.
financial institutions and
across international
borders.
9. Whether there are
ways to improve
CTR aggregation for
entities with common
ownership.
10. Whether financial
institutions should
be permitted to
streamline or otherwise
adjust, with respect
to particular types
of customers or
transactions, the
process for determining
whether activity is
suspicious or the
information included
in the narrative of a
suspicious activity
report.
Sections 6201-6216 Table of Contents—SectionsDivision F Title LXI Title LXII Title LXIII Title LIV Title LXV
National Relevant Date(s)
Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Title LXII—Modernizing the AML and CTF Reporting System
Streamlining 6204 11. Any other matter the January 1, 2022 Report must
requirements for secretary determines is include findings as
CTRs and SARS appropriate. well as proposed
12. Whether financial rules.
institutions should
be permitted to
streamline or otherwise
adjust, with respect
to particular types
of customers or
transactions, the
process for determining
whether activity is
suspicious or the
information included
in the narrative of a
suspicious activity
report.
13. Any other matter the
secretary determines is
appropriate.
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Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Title LXII—Modernizing the AML and CTF Reporting System
CTR and SAR 6205 Requires the secretary January 1, 2022 Secretary of the
dollar threshold of the Treasury, in Treasury must
reviews consultation with publish a report
regulators and other by January
relevant stakeholders, 1, 2022, that
to publish a report contains proposed
addressing whether the rulemakings.
dollar thresholds, including Report must be
aggregate thresholds, for updated at least
CTR and SARs should be once every five
adjusted. years for the
10-year period
starting January 1,
2021.
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National Relevant Date(s)
Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Title LXII—Modernizing the AML and CTF Reporting System
Sharing of 6206 Requires the director of TBD No official start
threat pattern FinCEN to publish a semi- date is provided for
and trending annual report on threat the first report.
information patterns and trends based
on SAR filings.
In each publication, the
director shall provide
financial institutions and
the federal functional
regulators with typologies,
including data that can
be adapted in algorithms
if appropriate, relating
to emerging money
laundering and terrorist
financing threat patterns
and trends.
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National Relevant Date(s)
Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Title LXII—Modernizing the AML and CTF Reporting System
Subcommittee 6207 Requires that the Bank January 1, 2021 Effective January February 4, 2021 - FinCEN issued a statement indicating it is
on innovation Secrecy Act Advisory 1, 2021, the BSAAG collaborating with the BSAAG Committee to design and plan for
and technology Group (BSAAG) establish must establish the the inaugural Financial Crimes Tech Symposium. The symposia
a “Subcommittee subcommittee. The will provide a platform for firms to review new technologies and
on Innovation and subcommittee will demonstrate proof of concept for a broad range of attendees,
Technology.” The purpose sunset on January including domestic and international financial regulators, regulated
of the subcommittee is to: 1, 2026, with an firms, technology providers, representatives from law enforcement
option to renew and national security agencies, and academics, among others. The
1. Advise the secretary annually after the symposium will build upon FinCEN’s Innovation Initiative. Plans on
of the Treasury how fifth year. the event will be announced at a future date.
supervisory agencies
can most effectively February 10, 2021 - The US Treasury hosted the inaugural US
encourage and Financial Sector Innovation Policy Roundtable on February 9-10,
support technological 2021, which was attended by policymakers, regulators, and private
innovations for AML sector representatives, to exchange views for collaborating
and CTF purposes. on policy issues and innovative technologies that support
2. Reduce foreseeable global financial integrity, while fostering economic recovery,
obstacles to innovation competitiveness, and financial inclusion.
that may arise from
existing regulations,
guidance, and
examination practices
applicable to financial
institutions complying
with BSA.
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National Relevant Date(s)
Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Title LXII—Modernizing the AML and CTF Reporting System
Subcommittee 6207 Requires that the Bank January 1, 2021 Effective January March 26, 2021 - FinCEN issued a report on its Innovation Hours
on innovation Secrecy Act Advisory 1, 2021, the BSAAG Program, which highlights its impacts and outlines its role in
and technology Group (BSAAG) establish must establish the supporting FinCEN’s future innovation efforts.
a “Subcommittee subcommittee. The
on Innovation and subcommittee will May 19, 2021 - BSAAG plenary session announced the launch of the
Technology.” The purpose sunset on January new subcommittees on Innovation and Technology and Information
of the subcommittee is to: 1, 2026, with an Security and Confidentiality.
option to renew
1. Advise the secretary annually after the May 26, 2021 - FinCEN will host Innovation Hours Program on
of the Treasury how fifth year. September 9, 2021, on privacy-enhancing technologies. The
supervisory agencies workshop will focus on the important role of privacy-preserving
can most effectively principles in developing technical solutions that enhance financial
encourage and services innovation while countering illicit activity and national
support technological security risks that undermine the integrity and opportunity of the US
innovations for AML financial system.
and CTF purposes.
2. Reduce foreseeable
obstacles to innovation
that may arise from
existing regulations,
guidance, and
examination practices
applicable to financial
institutions complying
with BSA.
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National Relevant Date(s)
Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Title LXII—Modernizing the AML and CTF Reporting System
Establishment 6208 Requires FinCEN and Dependent on when Under Section
of Bank Secrecy each federal functional FinCEN promulgates 6103, FinCEN
Act innovation regulator to appoint an regulations under is required to
officers “Innovation Officer” who Section 6103 promulgate
will coordinate with other and they become regulations on
Innovation Officers to: effective. information
sharing. FinCEN
1. Conduct outreach and federal
to law enforcement, functional
supervisory agencies, regulators
financial institutions, shall make
and those associated appointments
with financial within one year
institutions (e.g., service of the effective
providers, vendors, date of FinCEN’s
technology companies) promulgated
regarding innovative regulations.
methods, processes,
and new technologies
that will benefit
compliance with BSA
obligations.
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National Relevant Date(s)
Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Title LXII—Modernizing the AML and CTF Reporting System
Establishment 6208 2. Provide technical Dependent on when Under Section
of Bank Secrecy assistance or guidance FinCEN promulgates 6103, FinCEN
Act innovation on implementing regulations under is required to
officers innovative and Section 6103 promulgate
new technology by and they become regulations on
financial institutions, effective. information
professional sharing. FinCEN
associations, and and federal
parties related to functional
financial institutions regulators
to comply with BSA shall make
requirements. appointments
3. Explore private- within one year
public partnership of the effective
opportunities. date of FinCEN’s
promulgated
4. Develop metrics of
regulations.
success.
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National Relevant Date(s)
Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Title LXII—Modernizing the AML and CTF Reporting System
Testing methods 6209 Requires secretary of Requires FinCEN No specific date March 31, 2021 - The Office of the Comptroller of the Currency
and rulemaking the Treasury to issue a issue a rule is provided for the (OCC) and other agencies published a request for information to
rule specifying standards issuance of the rule gather information and comments on FIs’ use of AI (including ML)
for FIs’ testing of BSA or updates to the related to risk management practices, challenges, and benefits. The
compliance technology manual. comment window closed on June 1, 2021.
and related internal
processes and Federal April 9, 2021 - FinCEN sent a request for information on how risk
Financial Institutions management principles described in the “Supervisory Guidance
Examination Council on Model Risk Management” relate to systems or models used by
(FFIEC) to update the banks to assist in complying with the requirements of BSA laws and
FFIEC Manual accordingly. regulations.
The standards may
include:
1. An emphasis on using
innovative approaches
such as ML or other
enhanced data
analytics processes.
2. Risk-based testing,
oversight, and other
risk management
approaches of the
regime, prior to and
after implementation,
to facilitate calibration
of relevant systems
and prudently evaluate
and monitor the
effectiveness of their
implementation.
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National Relevant Date(s)
Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Title LXII—Modernizing the AML and CTF Reporting System
Testing methods 6209 3. Specific criteria for Requires FinCEN No specific date March 31, 2021 - The Office of the Comptroller of the Currency
and rulemaking when and how risk- issue a rule is provided for the (OCC) and other agencies published a request for information to
based testing against issuance of the rule gather information and comments on FIs’ use of AI (including ML)
existing processes or updates to the related to risk management practices, challenges, and benefits. The
should be considered manual. comment window closed on June 1, 2021.
to test and validate
the effectiveness April 9, 2021 - FinCEN sent a request for information on how risk
of relevant systems management principles described in the “Supervisory Guidance
and situations and on Model Risk Management” relate to systems or models used by
standards for when banks to assist in complying with the requirements of BSA laws and
other risk management regulations.
processes, including
those developed by
or through third-party
risk and compliance
management systems,
and oversight may be
more appropriate.
4. Specific standards
for a risk governance
framework for financial
institutions to provide
oversight and to
prudently evaluate
and monitor systems
and testing processes
both pre- and post-
implementation.
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National Relevant Date(s)
Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Title LXII—Modernizing the AML and CTF Reporting System
Testing methods 6209 5. Requirements for Requires FinCEN No specific date March 31, 2021 - The Office of the Comptroller of the Currency
and rulemaking appropriate data issue a rule is provided for the (OCC) and other agencies published a request for information to
privacy and information issuance of the rule gather information and comments on FIs’ use of AI (including ML)
security. or updates to the related to risk management practices, challenges, and benefits. The
6. A requirement that the manual. comment window closed on June 1, 2021.
system configurations,
including any applicable April 9, 2021 - FinCEN sent a request for information on how risk
algorithms and any management principles described in the “Supervisory Guidance
validation of those on Model Risk Management” relate to systems or models used by
configurations used banks to assist in complying with the requirements of BSA laws and
by the regime, be regulations.
disclosed to FinCEN
and the appropriate
federal functional
regulator upon request
Financial 6210 Requires the secretary January 1, 2022 Secretary of the
technology of the Treasury, in Treasury must
assessment consultation with submit a report by
regulators and other January 1, 2022.
relevant parties, to prepare
and submit a report
assessing the impact of
technology on financial
crime compliance.
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National Relevant Date(s)
Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Title LXII—Modernizing the AML and CTF Reporting System
Financial crimes 6211 Requires Treasury Periodic Secretary of the February 4, 2021 - FinCEN issued a statement indicating it is
tech symposium secretary, in coordination Treasury must collaborating with the BSAAG Committee to design and plan for
with the BSAAG periodically hold a the inaugural Financial Crimes Tech Symposium. The symposium
Subcommittee on symposium. will provide a platform for firms to review new technologies and
Technology and demonstrate proof of concepts for a broad range of attendees,
Innovation, to hold a including domestic and international financial regulators, regulated
periodic global symposium firms, technology providers, representatives from law enforcement
to promote greater and national security agencies, and academics, among others. The
international collaboration symposium will build upon FinCEN’s Innovation Initiative. Plans on
on using new technology the event will be announced at a future date.
to prevent, detect, and
investigate financial crime February 10, 2021 - The US Treasury hosted the inaugural US
and other illicit activity. Financial Sector Innovation Policy Roundtable on Feb 9-10, which
was attended by policymakers, regulators, and private sector
Attendees will include representatives, to exchange views for collaborating on policy
domestic and international issues and innovative technologies that support global financial
regulators, senior integrity, while fostering economic recovery, competitiveness, and
executives of regulated financial inclusion.
firms, technology
providers, law enforcement
and national security
agencies, academics, and
other relevant experts and
parties.
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National Relevant Date(s)
Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Title LXII—Modernizing the AML and CTF Reporting System
Financial crimes 6211 Symposium will include Periodic Secretary of the February 4, 2021 - FinCEN issued a statement indicating it is
tech symposium panels that will review Treasury must collaborating with the BSAAG Committee to design and plan for
new technologies and periodically hold a the inaugural Financial Crimes Tech Symposium. The symposium
demonstrate the proof symposium. will provide a platform for firms to review new technologies and
of concept and Treasury demonstrate proof of concepts for a broad range of attendees,
will provide reports including domestic and international financial regulators, regulated
containing policy clarity firms, technology providers, representatives from law enforcement
and guidance regarding and national security agencies, and academics, among others. The
the new technologies and symposium will build upon FinCEN’s Innovation Initiative. Plans on
practices presented at the event will be announced at a future date.
each symposium.
February 10, 2021 - The US Treasury hosted the inaugural US
Financial Sector Innovation Policy Roundtable on Feb 9-10, which
was attended by policymakers, regulators, and private sector
representatives, to exchange views for collaborating on policy
issues and innovative technologies that support global financial
integrity, while fostering economic recovery, competitiveness, and
financial inclusion.
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National Relevant Date(s)
Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Title LXII—Modernizing the AML and CTF Reporting System
Financial 6211 Requires FinCEN to brief April 1, 2021 Director of FinCEN March 26, 2021 - FinCEN conducts an Innovation and Emerging
Crimes Tech Congress on emerging must conduct a Technologies briefing to the Senate Committee on Banking,
Symposium technologies (e.g., AI, briefing by April 1, Housing, and Urban Affairs and the House Financial Services
digital identity, distributed 2021. Committee and Publication of Supporting Report on FinCEN’s
ledger), including: Innovation Hours Program. FinCEN also issues an Innovation
Hours Program report that discusses emerging themes from the
1. Status and monthly Innovation Hours sessions, the Program’s impact on federal
implementation of government policy and FinCEN’s priorities, and the Program’s role in
emerging technologies supporting FinCEN’s future innovation efforts.
within FinCEN.
2. Whether new
technologies can be
further leveraged to
make data analysis by
FinCEN more efficient
and effective.
3. Whether FinCEN
could better use new
technologies.
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National Relevant Date(s)
Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Title LXII—Modernizing the AML and CTF Reporting System
Financial 6211 4. Any identified best April 1, 2021 Director of FinCEN March 26, 2021 - FinCEN conducts an Innovation and Emerging
Crimes Tech practices or significant must conduct a Technologies briefing to the Senate Committee on Banking,
Symposium concerns related to the briefing by April 1, Housing, and Urban Affairs and the House Financial Services
new technologies with 2021. Committee and Publication of Supporting Report on FinCEN’s
respect to the US AML Innovation Hours Program. FinCEN also issues an Innovation
and anti-illicit financing Hours Program report that discusses emerging themes from the
efforts. monthly Innovation Hours sessions, the Program’s impact on federal
5. Policy government policy and FinCEN’s priorities, and the Program’s role in
recommendations to supporting FinCEN’s future innovation efforts.
improve communication
between private
sector, FinCEN, and
government agencies
using new technologies.
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National Relevant Date(s)
Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Title LXII—Modernizing the AML and CTF Reporting System
Pilot program 6212 Requires Treasury Requires the FinCEN Secretary of the
on sharing SAR secretary to issue rules issue a rule Treasury shall
information with establishing a pilot January 1, 2022 issue rules by
foreign affiliates program that would January 1, 2022.
allow FIs to share SAR The pilot program
information with their will terminate
foreign affiliates. The pilot January 1, 2024,
program is to terminate with the option to
three years after the extend for up to
enactment of AMLA, two more years.
except the secretary of
the Treasury may extend
the pilot program for no
more than two years after
submitting a report to
Congress on the necessity,
value, and operations of
the program.
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National Relevant Date(s)
Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Title LXII—Modernizing the AML and CTF Reporting System
Pilot program 6212 Secretary of the Treasury Within 360 days of Secretary of the
on sharing SAR shall provide updates on issuance of the rules Treasury shall
information with the pilot program: establishing the pilot issue rules by
foreign affiliates program January 1, 2022.
1. The degree of any Updates to the
information sharing pilot program are
permitted under the required within
pilot program and a 360 days of the
description of criteria secretary of the
used by the secretary Treasury issuing
to evaluate the rules and annually
appropriateness of the for three years
information sharing. thereafter.
2. The effectiveness
of the pilot program
in identifying or
preventing the violation
of a US law or regulation
and mechanisms that
may improve
that effectiveness.
3. Any recommendations
to amend the design of
the pilot program.
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National Relevant Date(s)
Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Title LXII—Modernizing the AML and CTF Reporting System
Financial 6213 Permits FIs to share January 1, 2021 Effective January
institutions’ compliance resources 1, 2021
sharing of in accordance with
compliance the October 3, 2018,
resources Interagency Statement on
Sharing BSA Resources.
OUTREACH.—The
Treasury secretary
and the appropriate
supervising agencies shall
carry out an outreach
program to provide
financial institutions with
information, including best
practices.
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Defense AMLA/ Notes Relating
(Note that many dates Latest
Authorization NDAA Summary are tied to the to Relevant
Developments
Act Title Name Section completion of other Date(s)
and Number action items)
Title LXII—Modernizing the AML and CTF Reporting System
Encouraging 6214 Requires periodic Periodic Supervisory
of information meetings between the Team must meet
sharing and secretary of the Treasury, periodically.
public-private supervisory agencies,
partnerships private sector experts,
national security, law
enforcement, and
other stakeholders to
examine ways to increase
cooperation between
private and public sectors.
Financial de- 6215 Requires comptroller January 1, 2022 Comptroller
risking general to conduct an general shall
analysis and submit submit a report by
a report to Congress January 1, 2022.
regarding de-risking Secretary of the
and the development Treasury must
of a strategy to reduce propose changes
consequences of de- and submit a
risking. It also requires report to Congress
the Treasury to report on within one year of
the comptroller general’s the comptroller
findings and strategy to general submitting
reduce de-risking. a report.
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