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The AML Community List - 2021: What will be Out and In for the Upcoming Year?

I have always enjoyed The Washington Post’s (and I am sure various other publications) list for the next year. The uniqueness is, of course, they eliminate a popular or hot issue with a new one for the next calendar year. To say 2020 was different would be a vast understatement. What was clearly the most chaotic and challenging time for the entire world will, in most cases, sadly stay with us for a long time to come. The following are my (and mine alone) predictions for 2021, which is extremely foolish given what we just went through (and are still dealing with), but limited to AML related issues and themes.

As David Letterman would have said, this is only an exhibition, not a competition -- so please, no wagering…



Covid Fraud

Garden variety fraud

Subjective review of risk assessments

Risk Assessment Regulation

Continued “talk” about information sharing

Actual improved and legal information sharing

Struggles for charities to receive financial access

FI’s providing access with regulator support

IRSCI Chief Don Fort (retired)

New Chief Jim Lee

BSA gaps in art and antiquities

Eventual BSA responsibilities

Geographic Targeting Orders renewed


Clarity on due diligence for Hemp businesses

Clarity on due diligence for marijuana businesses

Talk talk on sharing compliance resources

Actual sharing of resources

Support for AML “innovation”


Reliance on the 5th pillar on Beneficial Ownership

An actual, functioning Beneficial Ownership registry

Penalty against AML officer for BSA failures

More penalties

Virtual currency scams

More cases/oversight on virtual currency issues

Cybercrime as issue outside AML

AML departments co-owning cyber issues

Unclear regulatory expectations

AML reform including training for examiners

How to use AI in AML detection/reporting

Actual use of AI (where appropriate)

Media coverage on tax evasion/shell companies

Prosecution of tax evasion/shell companies

Training on financial aspects of terrorism

New focus on domestic terrorism

The FinCEN Files

More journalists covering ML issues

Studies on SARs/CTRS

Improved reporting and efficiencies

Secretary of Treasury/Attorney General

New administration—new priorities