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Five key points from FinCEN’s 180-day AML Reform Update

On June 30, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) released an update outlining its progress since the passage of the recent anti-money laundering (AML) reform law (AML Act) 180 days ago.[1] The Act contains the most significant changes to the AML regime since the 2001 USA PATRIOT Act, including requiring FinCEN to establish a registry of beneficial ownership information of certain companies, provide more transparency into its examination and supervision priorities, expand its scope to include areas such as antiquities dealers and virtual currency service providers, develop information sharing platforms and take measures to support innovation.

Six months after the passage of these ambitious reforms to the AML regime, FinCEN’s update shows that it has been steadily making progress on these directives. Notably, alongside the update it released its first-ever priorities document, which includes broad categories of financial crime (e.g., corruption, cybercrime, fraud) that go beyond AML and contemplate emerging technologies such as virtual currency. The update also highlights steps that FinCEN has taken to receive stakeholder feedback regarding its beneficial ownership registry, further its innovation agenda, contemplate a process for issuing no-action letters, and highlight financial crime issues with respect to art and antiquities.

While the update indicates that the agency is off to a good start in implementing the changes required by the AML Act, most of the actions thus far are “plans for a plan.” As such, the devil will be in the details as FinCEN continues to roll out implementing regulations and specific guidance.

This First take provides five key points about the update FinCEN released about their progress since the AML reform law’s passage. Here are the key takeaways:

  1. FinCEN releases first-ever AML priorities.
  2. The long-awaited beneficial ownership registry becomes closer to a reality.
  3. Focus on technology and innovation.
  4. No-action letter process in development.
  5. Antiquities and arts dealers put on alert.


[1] For more information on the AML Act, see PwC’s First take, Eight key points from the AML Reform Law (December 2020). 

First take

A publication of PwC's financial services regulatory practice

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Financial Crimes Unit, AML Leader, PwC US

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