U.S. Plays Catch-up to Close Long-Standing Gaps in Anti-Money Laundering Laws: Part One

Abstract

The U.S. Government finally seems to begin focusing on closing long-standing and significant gaps in existing anti-money and contra-terrorist financing laws (together, “AML”) that have been in existence for nearly a half-century and were more recently enhanced through the passage of the USAPATRIOT ACT (the “Patriot Act”) in 2001 following the September 11 attacks. The Patriot Act imposed massive new requirements on the U.S. financial industry, including banks and brokerage firms, and these requirements led to numerous enforcement actions and monetary fines, often exceeding one billion dollars, against financial institutions that did not comply with the new Patriot Act requirements.