Anti-Money Laundering Act (2020)

The Anti-Money Laundering Act of 2020 amended the United States anti-money-laundering framework through Division F of the fiscal year 2021 defence authorisation. It remains law. It revised policy, information-sharing, whistleblower, subpoena, examination and technology provisions within the Bank Secrecy Act architecture.

Distinct statutory components

The Act is not a single reporting database or sanctions authority. It expanded Treasury and FinCEN functions, created a beneficial-ownership information framework through the separately titled Corporate Transparency Act (2021), revised whistleblower awards and protections, and added section 6308 subpoena authority. That subpoena provision should be distinguished from the older correspondent-account provisions treated at USA PATRIOT Act Sections 317 and 319.

The law directs rulemaking and agency implementation. Enacted authority, a proposed rule, a final rule, guidance and an enforcement action are different legal stages. Claims that the Act created a global ledger or by itself exposes all foreign transactions exceed its text.

Beneficial-ownership reporting

FinCEN's March 2025 interim final rule revised Corporate Transparency Act reporting. It exempted United States-created entities and United States persons from beneficial-ownership information reporting while retaining obligations for qualifying foreign entities registered to do business in the United States, subject to the rule's terms. This did not repeal the Corporate Transparency Act or the Anti-Money Laundering Act.

The revision changes the reporting population and therefore any count of expected filers. Current numbers must state the rule version, entity class and extraction date rather than rely on earlier projections.

Whistleblowers and enforcement

FinCEN began accepting whistleblower tips in 2026. In March 2026 it proposed a rule concerning awards and protections. As at 30 July 2026, that rule had not been finalised. The statutory award framework should not be described as a completed payment process, and an allegation in a tip is not a legal finding.

The Act can strengthen financial intelligence, compliance and enforcement capacity, but outcomes require separate evidence from rule implementation, agency action and adjudication. Reports, subpoenas, investigations, civil penalties, charges and convictions must remain distinct.

Other implementation channels

The Act required a national anti-money-laundering and countering-the-financing-of-terrorism strategy and priorities, encouraged technology and information sharing, and revised examination and coordination arrangements. Financial institutions incorporate the national priorities through risk-based programmes under implementing rules and supervisory expectations. The priorities do not create a standalone offence or direct every institution to treat the same customer as high risk.

Section 6308 expanded subpoena authority concerning records held abroad by a foreign bank maintaining a correspondent account in the United States, subject to the statutory text. A subpoena seeks records; it does not freeze assets, establish sanctions liability or prove that the requested transaction was unlawful. Enforcement for non-compliance follows its own process.

Whistleblower tips can identify potential violations, while awards depend on statutory conditions and later implementation. The announced acceptance of tips does not establish how many claims will qualify or what amounts will be paid. Any award or penalty figure must state the provision, agency, date and final procedural status.

The Act's effectiveness should therefore be evaluated through defined outputs, including rules completed, useful information produced, examinations, enforcement outcomes and remediation, rather than through broad claims that it transformed global financial transparency.

Sources

1. Financial Crimes Enforcement Network, Anti-Money Laundering Act of 2020 hub (accessed 30 July 2026).
2. Financial Crimes Enforcement Network, March 2025 beneficial-ownership reporting revision.
3. Financial Crimes Enforcement Network, Whistleblower programme (accessed 30 July 2026).
4. Financial Crimes Enforcement Network, Proposed whistleblower rule, March 2026.