Enhanced US Subpoena Authority over Foreign Banks with US Correspondent Accounts: Watershed or Overreach? (February 2021)
Client Briefings
Introduction
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Congress passed the Anti-Money Laundering Act of 2020 on January 1, 2021 as part of the National Defense Authorization Act for Fiscal Year 2021.
The Act includes, among other significant updates to the Bank Secrecy Act and related U.S. anti-money laundering regimes, new and potentially groundbreaking authority for the U.S. Department of Justice and the U.S. Department of the Treasury to subpoena non-U.S. bank records stored outside the U.S., backed by hefty penalties for non-compliance.
