Congress enacted the Anti-Money Laundering Act of 2020 (AMLA) in January of this year, and much has been written about how it constitutes the most significant change to the U.S. anti-money laundering regime since the passage of the USA PATRIOT Act almost 20 years ago. However, one provision of the AMLA was added with little fanfare and minimal discussion, yet it could have a significant impact on foreign financial institutions doing business in the United States.