What you need to know

• The Anti-Money Laundering Act of 2020 (AMLA) gives the US Department of Justice (DOJ) significantly enhanced powers to combat money laundering. It coincides with recent pronouncements by the US government about countering corruption as a core national security interest, with a particular focus on reducing the ability of corrupt actors to use US and international financial systems to hide assets or launder proceeds of crime.
• The AMLA increases the DOJ's powers to subpoena the records of foreign banks with correspondent accounts in the US. The DOJ can now request "any records relating to the correspondent account or any foreign account at the foreign bank." Penalties for non-compliance include losing access to US banking services and substantial fines.
• The AMLA also requires certain companies registered to do business in the US to report beneficial ownership information to the US Treasury Department's anti-money laundering unit, the Financial Crimes Enforcement Network (FinCEN).
• Amended protections now provide potential whistleblowers with increased incentives for tip-offs about AML non-compliance. A whistleblower does not need to be a US citizen or resident, and the reported misconduct does not need to have occurred in the US, for the incentives to be available. Accordingly, it is possible for Australian whistleblowers, reporting on conduct occurring in Australia, to qualify for potentially sizeable rewards if US enforcement action and sanctions...

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