AML Act 2020
Also called anti-Money Laundering Act of 2020
The Anti-Money Laundering Act of 2020 is a major reform of US anti-money laundering law passed within the National Defense Authorization Act for fiscal year 2021. Enacted on 1 January 2021, it amended the Bank Secrecy Act, created the Corporate Transparency Act, expanded whistleblower awards and told FinCEN to make AML programmes more risk-based and effective.
How it works
The Act works mainly through rulemaking by FinCEN. FinCEN published the first national AML/CFT priorities on 30 June 2021. It wrote beneficial ownership reporting rules under the Corporate Transparency Act, later narrowed so that US companies no longer report. On 7 April 2026 it proposed a new AML/CFT programme rule, with matching proposals from the OCC, FDIC and NCUA.
For banks and other covered institutions, the Act shifts supervisory focus from process to results. Programmes are expected to target the national priorities and produce useful information for law enforcement. The Act also raised penalties for repeat violators, widened subpoena powers over foreign banks with US correspondent accounts and strengthened protections for whistleblowers who report BSA breaches.
The rules
Amended the Bank Secrecy Act to modernise AML/CFT programmes, create beneficial ownership reporting and expand whistleblower awards and enforcement powers.
Banks, money services businesses, broker-dealers and other BSA financial institutionsLists the government-wide threats, such as corruption, cybercrime, fraud and terrorist financing, that AML programmes are expected to take into account.
Financial institutions subject to BSA programme requirementsProposes risk-based, effectiveness-focused programme requirements under the Act, replacing FinCEN's July 2024 proposal. It was not final as of October 2026.
Banks, money services businesses, broker-dealers and other covered institutionsCommon questions
Is the Corporate Transparency Act part of the AML Act 2020?
Yes. The Corporate Transparency Act is Title LXIV of the AML Act. It created beneficial ownership reporting to FinCEN. FinCEN later revised the rules so that domestic US companies are exempt and only certain foreign reporting companies must file.
Does the AML Act 2020 apply outside the US?
It applies to US financial institutions and to activity within US jurisdiction. Foreign banks are affected through their US correspondent accounts, because the Act expanded the Treasury and Justice Department's power to subpoena records held by those banks abroad.
What does the Act say about whistleblowers?
It expanded the BSA whistleblower programme. People whose reports lead to successful enforcement can receive a share of the penalties collected, and they are protected from retaliation. FinCEN proposed rules for the programme on 1 April 2026.
Has FinCEN finished implementing the Act?
Not fully. Several rulemakings remain open, including the AML/CFT programme rule proposed on 7 April 2026. Firms follow the existing BSA programme rules until a final rule takes effect.
