What the law set in motion
The Anti Money Laundering Act of 2020 was passed as part of the annual defense authorization bill and became law on the first day of 2021. It was the broadest update to the Bank Secrecy Act framework in decades. It directed the Treasury to publish national anti money laundering priorities, pushed regulators toward risk-based programs and newer technology, and expanded the government's power to subpoena records from foreign banks that keep correspondent accounts in the United States. It also brought dealers in antiquities within the law's reach and increased penalties for repeat and egregious violators. Much of the act works through rules that FinCEN and the banking agencies write afterward, so its practical effect depends on regulations issued over time.
Ownership reporting and whistleblowers
The Corporate Transparency Act, part of the same legislation, created a federal registry of the people who own or control companies. That piece has changed more than any other: after court challenges and a change in Treasury policy, FinCEN issued rules in 2025 and 2026 removing the reporting duty for companies formed in the United States and their owners, leaving reporting mainly to certain foreign companies registered to do business here. Further changes remain possible, so a company should check the current rule rather than rely on an older memo. The act also rebuilt the Bank Secrecy Act whistleblower program, and later legislation extended it to sanctions violations, with awards tied to what the government collects. Protections against retaliation for employees who report were broadened at the same time.
What it means for your organization
For banks, money transmitters, broker-dealers, and casinos, the act mostly shows up in examinations and in how regulators expect programs to be tailored to actual risk. For fintech and crypto businesses, the question is often whether they are covered at all, and which obligations they inherit through a partner bank. For an individual who has seen violations, the questions are about how and where to report and how the report is protected. When we first talk, we work out which of these describes you, read the documents that prompted the question, and identify which rules apply now, including any whose start dates have been postponed. If an exam finding or agency inquiry is already open, we look at that first, since it usually carries its own response timeline.
