Farewell to 2021, and welcome 2022 — which hopefully will be better year for all. As we do every year, let’s look back — because 2021 was a very busy year in the world of money laundering and BSA/AML compliance, and 2022 is shaping up to be the same.
Indicative of the increased pace and breadth of activity in this space both, our list is bigger this year. We are highlighting 20 of our most-read blog posts from 2021, which address many of the key issues we’ve examined during the past year: the many permutations of the sprawling AML Act; the Corporate Transparency Act and beneficial ownership reporting; potential AML regulation of the real estate industry; criminal and civil money laundering and BSA enforcement cases; efforts to crack down on domestic and foreign corruption; digital assets and cryptocurrency; data privacy and ransomware; ESG and related social issues; the increasing focus on the potential AML obligations of so-called “gate keepers,” including lawyers; and more:
- U.S. Passes Historic BSA/AML Legislative Change
- Proposed Beneficial Ownership Reporting Regulations Under the CTA: Broad and Complex
- Real Estate and Money Laundering: FinCEN Issues Advanced Notice of Regulations for the Real Estate Industry
- FinCEN Identifies AML/CFT “Priorities” For Financial Institutions
- AML Act Adds Robust New Whistleblower Provisions for Anti-Money Laundering Violations
- Review, then Reform? AMLA Charts a Path for the Future of SARs and CTRs
- AML Act Information-Sharing and Privacy and Data Security Concerns
- ESG, AML Compliance and the Convergence of Social Concerns
- The OCC Embraces Technology, Proposes Exemption to SAR Requirements and Announces Acceptance of Distributed Ledgers and Stablecoins
- FinCEN and CFTC Reach Groundbreaking $100 Million AML Settlement with BitMEX
- Global Developments in AML and Virtual Assets: FATF Guidance and the Travel Rule, and U.S. Pronouncements on Stablecoins
- FinCEN Assesses Civil Penalty Against CommunityBank of Texas for AML Program Weaknesses
- The ENABLERS Act Seeks to Impose BSA/AML Requirements on an Array of “Middlemen” Professionals
- DOJ Fraud Section 2020 Year in Review: Money Laundering Statute Remains an Overseas Enforcement Tool
- President Biden Unveils Broad Vision to Crack Down on Foreign and Domestic Corruption
- FinCEN Issues Notice on Environmental Crimes and Illicit Financial Activity
- “Real Housewives” Star Indicted for Money Laundering and Fraud
- FinCEN Solicits Comments on AML Rules for the Antiquities Trade
- SEC Extracts AML Settlement From Broker-Dealer Based on Alleged Failure to Comply with “Five Essential Elements” of SAR Filings Regarding Cyber Crime
- U.S. Sentencing Commission Data on Money Laundering and BSA-Related Offenses Reveals: Courts Often Sentence Below the Guidelines Range
We now move on to 2022. This year also will be an important and interesting year for BSA/AML and money laundering issues, given the many forthcoming regulations and reports required by the AML Act and the Corporate Transparency Act, which will affect a broad variety of stakeholders. We look forward to keeping you informed throughout 2022 on these and other developments.
We also want to thank our many readers around the world who continue to make this blog such a success. The feedback we receive from financial industry professionals, compliance officers, in-house and external lawyers, BSA/AML consultants, government personnel, journalists, and others interested in this field is invaluable, and we hope you will continue to share your perspectives with us. We pride ourselves on providing in-depth discussions of the important developments in this ever-evolving area.