The National Defense Authorization Act, (NDAA) became law on Jan. 1, 2021, after the U.S. Congress overrode a presidential veto. Division F of the Act is the “Anti-Money Laundering Act of 2020” (AMLA). This month’s column highlights a few of the AMLA provisions that may be of interest to international banks.

Registration of Beneficial Ownership

As I noted in my Jan. 12, 2021 column, one of the amendments is aimed at making banks and other financial institutions that need to obtain beneficial ownership of certain of their customers easier. Under current regulations, banks and other financial institutions that maintain required customer identification programs must, when opening up accounts for certain legal entities, obtain beneficial ownership information on (1) individuals owning 25% or more of the entity and (2) an individual person with significant control over the entity such as a president or chief executive officer. These financial institutions long have felt it was burdensome to have to obtain that ownership information and new entity customers may be reluctant to provide it.

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