IT'S HERE - NOW WHAT? - The Anti-Money Laundering Act of 2020: riskCanvas
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WHITE PAPER The Anti-Money Laundering Act of 2020: IT’S HERE - NOW WHAT? The most significant financial crime regulation passed in two decades increases the expectation of AML and CFT efforts for U.S. Institutions. This whitepaper provides a summary of the regulation and actionable insights.
2 The AMLA of 2020
Table of Contents
01 Preface
02 Summary of The AMLA of 2020
03 The AMLA 2020 Will Drive Change for FIs
04 The Specifics of AMLA 2020
05 What Financial Institutions Can Do Now
06 Conclusion
07 Note on New Beneficial Ownership Requirements
White Paper 3
Preface
1
The Anti-Money Laundering Act of 2020 The US will set AML/CFT national
is the most significant addition to financial
priorities. These national priorities
crime regulation since the USA PATRI-
will sharpen regulatory and law
OT Act passed nearly 20 years ago. The
enforcement focus. Financial
new law requires the US government to
set national Anti-Money Laundering and institutions must align their programs
Counter Terror Financing priorities to ex- with these priorities as part of a risk-
pand FinCEN’s power, directs regulator based program to combat money
and law enforcement agencies to better laundering and the financing of
coordinate, and increases Congressional terrorism.
2
oversight of the Department of Justice The AMLA 2020 increases FinCEN’s
and Treasury, including FinCEN. power. FinCEN’s responsibility in both
When Congress grants regulators and regulatory examinations and law
law enforcement more authority to fight enforcement investigations increases
financial crime and explicitly directs them substantially, as does Congress ’s
to do more with that power, institutions oversight of FinCEN. This new power
and those that lead Anti-Money Launder- and Congressional oversight means
ing and Counter Terror Financing (AML/ a greater US government emphasis
CFT) programs must take notice. The An- on AML/CFT regulation and
ti-Money Laundering Act 2020 (AMLA enforcement. Financial institutions
2020) creates new compliance require- must prepare for more rigorous
ments and increases expectations that AML/CFT examinations, particularly
financial institutions improve their AML/ around suspicious activity detection,
CFT programs.[1] investigation, and reporting
AML officers must assess the AMLA’s processes.
impact on their existing compliance pro-
3
grams. In particular, AML officers should The AMLA 2020 mandates regulators
evaluate whether their current program remove barriers and encourage
will withstand inevitable heightened reg- financial institutions to modernize
ulatory and enforcement scrutiny. A few of AML/CFT software systems. The law
the new AMLA 2020 requirements of in- requires regulators to specify how
terest to AML/CFT officers include: banks should upgrade technology.
Financial institutions will feel
pressure to modernize AML/CFT
technology systems which in many
cases, have not be updated in more
than a decade.
[1] “Regulators” refers collectively to the Federal functional regulators defined by Gramm-Leach-Biley Act to include the Federal Reserve,
the Office of Comptroller of the Currency, the Federal Deposit Insurance Company, the National Credit Union Association Board, and the
Securities and Exchange Commission. It also refers to relevant State regulators. “Law enforcement” refers to Federal law enforcement
agencies.
4 The AMLA of 2020
Summary of The AMLA of 2020
The purposes of the AMLA 2020, which became law on January
1, 2021, are:
1. To improve coordination and information sharing among
regulatory, law enforcement, national security agencies,
intelligence agencies, and financial institutions.
2. To modernize AML/CFT laws to adapt to the government
and private sector to new and emerging threats.
3. To encourage AML/CFT technological innovation by
financial institutions.
4. To emphasize the financial institution’s AML/CFT policy,
procedures, and controls should be risked-based.
5. To establish uniform beneficial ownership reporting
requirements.
It appears the purpose of the AMLA 2020 is to strengthen
the “whole of government” approach to AML/CFT efforts.
Prior AML/CFT laws, like the USA PATRIOT Act, emphasized
financial institutions be required to create and maintain
specific programs like Customer Identification Programs
and SAR reporting. The AMLA 2020 focuses less on new
requirements for financial institutions and much more on
new responsibilities and requirements on FinCEN, DOJ, and
regulators. In particular, FinCEN’s role expands to become
the national coordinator of AML/CFT efforts among law
enforcement, regulators, national security and intelligence
agencies, and the private sector. With the new power, FinCEN
will be subject to more Congressional oversight.
The new emphasis on government coordination does not
diminish the fact that financial institutions will need to update
old AML/CFT practices and implement new ones. After all,
financial institutions are a crucial part of the nation’s efforts to
detect and prevent crime, and it is clear that the AMLA 2020
heightens the importance of AML/CFT program compliance.
White Paper 5
The AMLA 2020 Will Drive
Change for FIs
The AMLA 2020 mandates FinCEN, law capable of identifying, tracking and tracing
enforcement, and regulators to strengthen money laundering and terrorist-financing
the US AML/CFT regime. As Congress seeks networks in order to conduct and support
to determine the AMLA’s effectiveness, it criminal AML and CFT investigation(.)” In
will press regulators and law enforcement order to the Analytical Hub to be effective,
to ensure financial institutions improve their FinCEN must rely on the quality of data it
AML/CFT programs. As a result, FinCEN and receives, in this case SARs, CTRs, and other
the regulators will require financial institutions BSA reports. Increased emphasis will be
to strengthen their AML/CFT programs. placed upon whether SARs and CTRs are
filed on time, are complete and are accurate.
New requirements placed on FinCEN and Financial institutions should be aware that
regulators inevitably cascade onto financial as regulators intensify examinations, what
institutions. To illustrate this point, take the was considered adequate for AML/CFT
AMLA 2020 mandate that FinCEN create a compliance over the past few years may no
new “Analytical Hub” with “financial experts longer be so.
6 The AMLA of 2020
The Specifics
of AMLA 2020
National AML/CFT Priorities The AMLA 2020 does not change the
regulator’s role in conducting AML/CFT
Will Focus the Government’s examinations. However, the AMLA 2020
Attention requires examiners from each agency to
receive annual training. The training must
By July 1, 2021, the Secretary of the Treasury,include financial crime patterns and trends,
consulting law enforcement, national security why law enforcement sees AML/CFT
agencies, intelligence agencies, and state programs as critical to its missions, and the
and federal regulators must publicize national effects of de-risking. This annual training
AML/CMT priorities. These priorities must serves to focus the examiner’s attention on
be consistent with the National Strategy for the national AML/CFT priorities.
Combating Terrorist and Other Illicit Finance,
last published in February 2020. The Secretary An often-heard complaint among AML/CFT
must update the national AML/CFT priorities officers is that regulatory examinations are
at least every four years. not aligned with the BSA’s purpose and intent,
because examiners sometimes focus on literal
Strengthening FinCEN and compliance versus effective compliance. It
Congressional Oversight would seem lawmakers are aware of this
complaint. By requiring annual training,
Increases Expectations on ensuring examiners focus on the issues
Financial Institutions FinCEN considers most important, financial
institutions should see more predictable and
The AMLA 2020 directs FinCEN to increase its consistent examinations in 2021 and beyond.
domestic and foreign staff, work closely with
federal and state regulators, and develop and The AMLA 2020 clarifies that Congress now
provide expert support to law enforcement will exercise more oversight of FinCEN than
and national security agencies. Notably, the it has in the past. With FinCEN’s increased
AMLA 2020 requires FinCEN now regularly budget and responsibility comes increased
report its activities to Congress, exposing the accountability.
bureau to more scrutiny.
White Paper 7
Patrick McHenry is the top Republican on understand the need for this legislation.
the House Financial Services Committee, No such data was forthcoming. Rather,
the Committee responsible for the FinCEN gave anecdotes of very scary
House’s contributions to the AMLA 2020. stories to justify the need for a new
Congressman McHenry’s December 8, reporting regime. It is my expectation
2020 remarks to the House clarify an that FinCEN will provide Congress with
influential Member’s view of FinCEN. Part of the necessary data to justify this new
McHenry’s statement includes the following: reporting regime and the burdens it is
placing on legitimate companies.”
“For far too long FinCEN has evaded
any type of congressional check on its AML officers, their teams, and financial
activities. Yet, it has amassed a great deal service institution executives should
of authority. Now, Congress will shine a read McHenry’s words closely. Congress
light on its operations. It is my expectation expects FinCEN to move past “anecdotes
that FinCEN will provide Congress with of very scary stories” and now provide
hard data on its effectiveness in targeting “hard data on its effectiveness…”. An active
bad actors(.)” Congress impacts AML/CFT compliance.
Congressional investigations of Riggs Bank
McHenry goes on to say; and HSBC ushered in periods of intense
and punitive regulatory enforcement. To
“In the months leading up to the House’s avoid future Congressional heat, regulators
consideration of H.R. 2513 last October, and law enforcement must show Congress
I sought data from FinCEN and from that they are vigorously examining financial
the Treasury Department, along with institutions’ compliance with the AMLA
the Department of Justice, to better 2020.
Congress expects FinCEN to move past
‘anecdotes of very scary stories’ and now
provide ‘hard data’ on its effectiveness…
8 The AMLA of 2020
Specifics
Continued
AML/CFT Data Analysis Congress has reacted to banks’ legitimate
complaints that regulators have focused on
Required and Data Sharing SAR quantity rather than quality, and FinCEN
does not provide enough feedback on SARs
For years, AML professionals have wondered
filed by banks. As a result, the AMLA 2020
if all the SARs and CTRs filed are useful to
instructs FinCEN to publish twice a year
law enforcement. It seems Congressman
the “Sharing of Threat Pattern and Trend
McHenry has the same question. The AMLA
Information” report. FinCEN will share with
2020 requires this question be answered
financial institutions and regulators financial
every year. By December 31, 2021, and every
crime typologies as well as data about
year onward, the Attorney General working
typologies that can be used to improve
with Federal law enforcement and intelligence
transaction monitoring algorithms.
agencies, and the regulators must submit to
the Treasury Department (FinCEN) a, “report
In addition to this twice a year report, the AMLA
that contains statistics, metrics, and other
2020 establishes a “FinCEN Exchange,” a
information on the use of the data derived
public – private information sharing partnership
from financial institutions reporting under the
between law enforcement, regulators, and
Bank Secrecy Act.”
financial institutions.
The report is required to publish whether the
BSA data (SARs, CTRs for example) includes AML/CFT Modernization
“actionable information” that leads to law Means AML/CFT Programs
enforcement action such as subpoenas, Must Modernize
warrants, or arrests.” The annual report must
also state how quickly the SARs and CTRs led to It’s been nearly two decades since the USA
law enforcement action, whether subsequent PATRIOT Act became law. To comply with
investigation subjects were individuals or requirements to identify customers, monitor
businesses, how often investigations involve transactions, and report suspicious activity,
cross border transactions, and maybe most financial institutions spent heavily on software.
importantly, how often BSA information Unfortunately, transaction monitoring
provided by financial institutions leads to software generates unmanageable numbers
arrests, convictions, forfeitures, or actions by of low value or false positive alerts, burdening
national security or intelligence agencies. In investigators and jeopardizing compliance.
other words, Congress wants to see evidence While the exact cost of outdated AML/CFT
the BSA is working. software is probably incalculable, no one
disagrees that hundreds of millions of dollars a
White Paper 9
year is spent on AML/CFT work that produces CFT technology. The standards “may include
little value. an emphasis on using innovative approaches
such as machine learning or other enhanced
Despite this massive cost, financial data analytics processes.” The new standards
institutions are slow to scrap old systems. may also include specific criteria for how
Because replacing systems is costly and risky, institutions conduct risk-based comparison
many banks decide that keeping existing testing of new technology against existing
applications is better than purchasing new systems. This allows new technology to be
software. validated as effective before and after new
software is implemented, bringing clarity to
Realizing this, the AMLA 2020 incentivizes a vexing problem – how to transition from
government agencies and financial institutions old monitoring systems to new monitoring
to modernize AML/CFT technology and systems without running afoul of regulators.
promotes using machine learning and artificial With clear standards on replacing outdated
intelligence to do so. systems, financial institutions are more likely
to act, accelerating much-needed financial
The Bank Secrecy Act Advisory Group or crime compliance technology change.
“BSAAG” was formed by The Annunzio-
Wylie Anti-Money Laundering Act of 1992. To emphasize the significance of these new
The BSAAG is a group of government and technological testing standards, the AMLA
industry executives whose purpose is to 2020 directs that the FFIEC BSA/AML
advise the Secretary of Treasury on AML/ Examination Manual be updated to include
CFT issues. The AMLA 2020 creates a new them. By creating and documenting new
BSAAG “Subcommittee on Innovation and uniform technology testing requirements,
Technology” whose mission is to advise financial institutions now have a published,
Treasury on how Federal regulators “can consistent process to follow when
most effectively encourage and support implementing new software.
technological innovation” in AML/CFT
programs. In addition, the Subcommittee is In addition to promoting technological
to “reduce…obstacles to innovation that may innovation as a means to modernize, the
arise from existing regulations, guidance, and AMLA 2020 codifies into law its October
examination practices…” 3, 2018, Interagency Statement of Sharing
Bank Secrecy Act Resources [INSERT LINK].
With the AMLA 2020 now specifically directing In that statement, Federal regulators permit
regulatory agencies to “reduce examination institutions to enter into agreements to “pool
and guidance obstacles” to technological human, technology, or other resources to
innovation, the time for meaningful AML/CFT reduce costs, increase operational efficiencies,
software modernization is here. and leverage specialized expertise.” Perhaps
the AMLA 2020 will spur smaller institutions
Perhaps most significantly, the AMLA 2020 to form AML/CFT consortiums where they
directs Treasury to specify standards financial can combine staff and technology systems to
institutions will follow to implement new AML/ improve compliance and manage costs.10 The AMLA of 2020
What Financial Institutions
Can Do Now
The AMLA 2020 significantly changes many aspects of AML/CFT compliance. FinCEN’s new
responsibilities will lead to increasing attention on financial institution AML/CFT programs. The
push to modernize technology will accelerate much-needed software changes, and greater
coordination between regulators and law enforcement are all reasons financial institutions
need to look closely at their 2021 – 2022 AML/CFT plans. In particular, in response to the
AMLA 2020, the following AML/CFT program areas should be assessed:
1 2 3 4
Updating Risk Assessments Updating Customer Risk Updating AML/CMT Assessing AML/CFT
to incorporate national AML/ Rating and De-Risking technology systems detection, staffing needs
CMT priorities Processes investigation, and reporting
Update Enterprise AML/CFT Risk Assessment to Include
National Priorities
By July 1, 2021, The Secretary of Treasury the US government may prioritize, AML
must publish the US national AML/CFT officers should read the 2020 National
priorities. Once published, the national Strategy for Combating Terrorist and Other
priorities will drive the US regulatory and Illicit Financing, whose primary author is the
enforcement agenda. As a result, regulators US Department of Treasury. Assessing the
will examine how financial institutions adapt AML/CFT risks Treasury called out in 2020 is
their AML/CFT programs to align with the US an excellent place to understand Treasury’s
national priorities, starting with examining financial crime-fighting priorities. The risks
how each institution updates its AML/CFT Treasury identified in 2020 include narcotics
Risk Assessment. It will be expected that trafficking, terrorist financing, weapons of
every financial institution’s AML/CFT Risk mass destruction proliferation, organized
Assessment includes assessing whether crime, human trafficking, corruption,
the national priorities present a risk to your beneficial ownership identification, real
financial institution and, if so, what is that estate purchases and sales, correspondent
risk, how is that risk identified, mitigated, banking, cash and trade-based money
managed, and tracked. Without this new laundering, digital currencies, complicit
work, the AML/CFT risk assessment will be actors within financial institutions,
insufficient. gatekeeps like attorneys, money service
businesses, securities broker-dealers, and
The 2021 national AML/CFT priorities will casinos. It makes sense to see these risks
not be published for six months. However, are addressed in your most recent AML/CFT
in anticipation of understanding which risks Risk Assessment.White Paper 11
After decades, AML laws have been updated and national
security and law enforcement officials are combatting
emerging threats by working on updating obsolete tools
to prevent kleptocrats and criminals’ from sophisticated
strategies.
Ian Gary, executive director of the FACT Coalition
Update Customer Risk Rating and De-Risking Processes
With national AML/CFT priorities established The AMLA 2020 includes a “sense of
by July 1, 2021, AML programs will be Congress” section in which lawmakers
expected to review and update Customer acknowledge the unintended consequence
Risk Rating (CRR) policies and procedures. of de-risking embassies, charities, MSBs,
Treasury’s published national AML/CFT and foreign correspondent accounts. The
priorities will identify specific types of legislation states that because many of these
customers, products, services, and locations “underserved individuals” and organizations
it considers high risk. Financial institutions are excluded from the banking system, their
must determine if their current High-Risk need to send and receive funds is driven into
Customer identification, enhanced due less transparent markets. In other words,
diligence, and on-going monitoring policies, it is possible de-risking ends up increasing
procedures, and processes include all those money laundering and terrorist financing
Treasury calls out. If not, then updating risk.
Customer Risk Rating and Enhanced Due
Diligence policies and procedures are The Government Accounting Office (GAO)
required. is directed to deliver a De-Risking Analysis
report to Congress by December 31, 2021.
The AMLA 2020 addresses an issue that Once this report is published, the AMLA 2020
has challenged AML/CFT departments instructs the federal functional regulators
since 2004 when specific categories of to spend 2022 updating examination
customers became “too high risk.” In 2004, standards and regulatory guidance to
these “too high-risk customers” included “consider the adverse consequences of de-
foreign embassy, Money Service Business risking entire categories” of customers. The
(MSB), and charity accounts. Since 2004, law explicitly cites charities, embassies, and
other customers, including many foreign money service businesses as account types
correspondent banking accounts, are also regulators must considering in drafting new
considered especially high risk. As a result, de-risking (or “non-de-risking”) rules.
many institutions have policies that prohibit
the banking of these types of customers, a At this point, financial institutions should
process known as “de-risking.” continue to refine their de-risking policies
while paying attention to forthcoming
government guidance.12 The AMLA of 2020
Upgrade Software and Incorporate New
Technology Approaches
The best way to strengthen AML/CFT In 2021 AML/CFT officers need
compliance is to measure how useful to look more seriously at new
law enforcement finds SARs. The detection and reporting software
AMLA 2020 requires DOJ to report to as well as incorporating modern
Congress every year “the frequency computer science approaches
with which the reported data (SARs like machine learning. For some
and CTRs) contain actionable institutions, this may mean installing
information that leads to” law new transaction monitoring and
enforcement investigations, arrests, case management applications.
national intelligence action, and other For many other institutions, it may
national security or legal process. As mean looking closely at software
a result, financial institutions should hosted in the cloud, also known as
expect more regulatory scrutiny of Software as a Service, or SaaS, where
their suspicious activity detection implementation time, expenses, and
and reporting programs. on-going maintenance costs are
reduced.
Financial institutions must
demonstrate they have effective Regardless of whether institutions
software systems, people, and install or subscribe to new software
processes to file timely, accurate, systems, all AML/CFT officers should
and complete SARs. Lacking this consider how modern approaches will
capability means inevitable AML/ strengthen compliance. In addition to
CFT program failure, as it always has. machine learning, AML/CFT officers
should consider improvements
Congress is telling FinCEN to Robotic Process Automation (RPA)
modernize its operations, and the and data analytics brings to everyday
AMLA 2020 is pushing industry to AML/CFT work. RPA can automate
do the same. As a result, financial much of the time-consuming data
institutions must consider that using gathering investigators endure.
software installed 10 or 15 years ago Better data analysis can reveal
that buries analysts and investigators inefficient processes, measure
under piles of false-positive alerts, individual investigator performance,
distracting them from work that and identify transactions and
matters, is no longer acceptable. customer behavior that can improve
detection scenarios.White Paper 13
Assess Staffing Needs
Modernizing AML/CFT should also
prompt assessing long-standing
compliance staffing approaches.
For 20 years, the response to new
AML/CFT requirements was to add
more people, which as a practice is
unsustainable. Much of the work that
drives hiring additional people stems
from outdated software that generates
too many alerts. As better software
proliferates, AML leaders must assess
current approaches to staffing.
Modern software changes how AML/
CFT teams collect and access data.
Better software produces better
alerts, which in turn produces more
useful investigations and better SARs.
However, because of the massive
volume of financial transactions
worldwide, and the fact that money
laundering and terror financing often
look like legitimate economic activity,
even better software will continue to
produce alerts that do not end up as
SARs. 2021 is time for AML/CFT leaders
to think about alternatives to hiring and
maintaining large staffs dedicated to
high volume repetitive work.
Over the past several years, institutions
began to outsource high volume,
simpler, repetitive work. It is time to
assess an AML/CFT department’s
makeup and determine which tasks
require more experience, more specific
knowledge, and are of higher value.
Perhaps these jobs remain in-house,
and the more straightforward, repetitive
work is outsourced or, as the AMLA
2020 codifies into law, shared with
other financial institutions.14 The AMLA of 2020
Conclusion
Writing the numerous regulations
that implement the directives of new
laws takes time. It also takes time for
regulators to incorporate the new
regulations into their examinations.
Using the USA PATRIOT Act passed in
late 2001 as an example, it took about a
year before the first signs of intensified
regulatory examinations uncovered
glaring weaknesses in AML/CFT
programs.
Of course, in 2021, AML/CFT programs
are more sophisticated and seasoned
than 20 years ago. However, the
US government and most other
governments around the world have
massively grown their regulatory
and enforcement infrastructure to
review, assess, and determine the
effectiveness of AML/CFT programs.
The AMLA 2020 further expands
this power in the US. With it comes
increased expectations from Congress
and the public that financial institutions
will do more to detect, prevent, and
report financial crime. For institutions
that do not meet the new standards,
the consequences will be severe.
As 2021 begins, every financial
institution’s work around assessing,
strengthening, and modernizing their
AML/CFT programs must begin.White Paper 15
Note on New Beneficial
Ownership Requirements
“The Corporate Transparency Act” is existing policy and procedures. It is
enacted as part of the AMLA 2020. likely Financial institutions will need to
To AML/CFT professionals, this Act update their policies and procedures
may become known as something to include how they collect FinCEN
like the “Beneficial Ownership CTA registration numbers, how to
Database.” Under the AMLA 2020, request customers approve access
financial institutions and their AML/ to the FinCEN database, procedures
CFT departments are not permitted if customers deny access to the
access to the Beneficial Ownership database, and the processes the
Database except only when customers financial institution undertakes to
give permission for the bank to do access the Database. Policies will
so. Instead, FinCEN maintains the also need to include requirements to
database for use by law enforcement document results and maintain the
and other government agencies. Strict security of those results. Until 2022,
procedures will govern access to the financial institutions must continue
Beneficial Ownership Database, and to collect beneficial ownership
all information must be protected and information as they do now. After
considered confidential. 2022, changes to beneficial ownership
information may change, or they may
The Corporate Transparency Act not.
(CTA) is to take affect by January
1, 2022. By that time FinCEN will Requiring corporate entities to register
have established a database to store should make gathering Beneficial
the collected beneficial ownership Ownership information easier for
information. FinCEN is instructed to financial institutions. Because
work with states to where feasible registering with FinCEN will be
to use existing business registration required, all companies will have the
processes to collect beneficial necessary documents and receive a
ownership information. Over the next FinCEN registration number proving
year, FinCEN will need to publish a they have registered. Perhaps as the
considerable number of regulations Database and the registration process
to govern the CTA. AML/CFT officers matures, financial institutions can
will need to follow these regulations fulfill their Beneficial Ownership due
to understand how the new beneficial diligence requirements merely by
ownership information collection obtaining and verifying the FinCEN
rules will impact financial institution’s registration number. One can hope.ABOUT riskCANVAS, A GENPACT COMPANY
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