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With bipartisan support and overriding (for the first and only time during the Trump presidency) a presidential veto, Congress passed the National Defense Authorization Act (“NDAA”) on January 1, 2021.
1 As part of the NDAA, Congress enacted the most comprehensive and substantial changes to the anti-money laundering and counter-terrorism financing laws, the Anti-Money Laundering Act of 2020 (“AMLA”), since the USA PATRIOT Act amended the Bank Secrecy Act (“BSA”) in 2001. While the AMLA expressly addresses defense and national security concerns regarding money laundering and terrorism, the wide-ranging legislation, which expands the government’s enforcement and investigative authority, as well as its access to information, has significant implications for government investigations generally.