2021 Anti-Money Laundering and Sanctions Year in Review
2021 was a precedent-setting year for anti-money laundering ("AML") enforcement and legislation. The digital assets industry continued to grow exponentially, driving the associated AML risks to the forefront of regulatory concerns. In the United States, the new administration established corruption, including money laundering, as a core national security interest. Legislators and regulators alike called for a "whole of government" approach to combatting illicit activity associated with cryptocurrencies, and federal agencies—from OFAC to the FDIC—issued long-awaited guidance for the virtual asset industry.
In the European Union, lawmakers introduced a comprehensive legislative package to harmonize the Union's approach to AML and countering the financing of terror ("CFT"). The proposal calls for the creation of a new AML authority and advances efforts to establish a "single rulebook" for AML/CFT in the European Union.
In Mainland China, new legislation expanded the list of entities subject to AML requirements to include loan companies, insurance agents, and insurance brokers, among others. In Australia, legislative amendments were enacted to reform certain customer due diligence and identification procedures.
This Year in Review explores the above developments and discusses other notable legislative and enforcement activity, including cross-border and intergovernmental initiatives. The Year in Review also provides an outlook on emerging trends and the resulting implications for financial institutions in 2022 and beyond.
