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After reviewing how the AMLA expands the BSA’s goals, we look at which AMLA provisions have the most impact on BSA compliance, including the AMLA’s emphasis on information sharing, the Financial Crimes Enforcement Network’s “national priorities” and the value of threat pattern and trend information to bank compliance efforts, and the AMLA’s expansion of the U.S. government’s authority to subpoena information from foreign financial institutions that maintain correspondent banking relationships with U.S. banks. We also review the CTA’s new beneficial ownership reporting requirements and discuss how they interact with existing customer due diligence (CDD) requirements and the need to align CTA and CDD regulations.
Peter Hardy and Terence Grugan, Ballard Spahr partners and co-leaders of the firm’s AML Team, host the conversation.
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