Strategy Includes Professionals Not Yet Covered by BSA
On May 13, 2022, the U.S. Treasury (“Treasury”) released its 2022 Strategy for Combatting Terrorist and Other Illicit Financing (“2022 Strategy”). The proposed 2022 Strategy, prepared pursuant to Sections 261 and 262 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), outlines four goals to address the key risks identified by the 2022 National Money Laundering, Terrorist Financing, and Proliferation Financing Risk Assessments:
- Increasing transparency and closing legal and regulatory gaps in the U.S. Anti-Money Laundering / Combating the Financing of Terrorism (“AML/CFT”) framework exploited by bad actors;
- Making the AML/CFT regulatory framework for financial institutions more effective and efficient;
- Enhancing operational effectiveness in combating illicit finance; and
- Utilizing technological innovation to combat illicit finance risks.
The 2022 Strategy is incredibly broad, identifying sixteen threats and vulnerabilities to the AML/CFT system as top priorities, and providing fourteen separate supporting actions necessary to achieve Treasury’s four goals outlined above. This post summarizes the priorities outlined in the 2022 Strategy, and details the specific supporting action targeting financial intermediaries and gatekeepers not presently covered by the Bank Secrecy Act (“BSA”), such as investment advisors, lawyers and accountants.