Pursuant to Sections 261 and 262 of the Countering America’s Adversaries Through Sanctions Act, the US Department of the Treasury has issued the 2020 National Strategy for Combating Terrorist and Other Illicit Financing, in an effort to modernize the US anti-money laundering and anti-terrorism financing regime fifty years after the enactment of the US’ first AML law, the Currency and Foreign Transactions Reporting Act of 1970. Other laws and implementing regulations have since been added to the arsenal of available AML/CFT provisions, and are collectively referred to as the Bank Secrecy Act.
The National Strategy 2020, which builds on the national strategy document of 2018, identifies money laundering, drug trafficking, terrorist financing, human trafficking, corruption, organized crime, and the proliferation of weapons of mass destruction as the most significant illicit finance threats to the US. It describes a road map for increasing transparency and closing gaps in the legal framework, improving efficiency in the regulation of financial institutions, and enhancing the operational framework for AML/CFT implementation and enforcement. Specifically, the new National Strategy points to key actions such as requiring companies to report beneficial ownership, promulgating regulations that require banks that do not have a federal functional regulator to implement AML programs, expanding the regulatory framework to include digital assets, and minimizing the risks of using real estate purchases to launder illicit proceeds.