Global enforcement actions and penalties for non-compliance with anti-money laundering (AML) regulations have been on the rise. Recent changes to the U.S. AML regime included in the National Defense Authorization Act for Fiscal Year 2021 (NDAA) have significantly expanded the government’s ability to pursue perpetrators of financial crime, following similar requirements already in place in Europe and the United Kingdom, and to enforce compliance rules and expectations.
FRA Partner Emma Hodges and Matt Reinhard, Member at Miller & Chevalier, will moderate a fascinating conversation with our panelists Charlie Steele, FRA Partner and former FinCEN Deputy Director and OFAC Chief Counsel; Brian Flemming, Member at Miller & Chevalier; and Sarah Runge, Global Head FCC Regulatory Strategy at Credit Suisse, on the current state of AML implementation and enforcement, including:
- The impact of key personnel appointments within the Biden Administration
- Significant changes enacted in the NDAA, including new beneficial owner disclosure requirements, expansion of authorities to cover nontraditional “financial institutions,” and expanded subpoena power and information-sharing authorities
- Trends in AML activity and enforcement, ranging from trade-based money laundering and lessons learned from the Russian Laundromat scheme to the intersection of AML and sanctions enforcement, and a new focus on secondary providers beyond “the big banks”