Treasury Announces 2020 National Illicit Finance Strategy

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The U.S. Department of the Treasury on February 6, 2020, issued the 2020 National Strategy for Combating Terrorist and Other Illicit Financing (2020 Strategy). This release provides a roadmap to modernize the U.S. anti-money laundering/countering the financing of terrorism (AML/CFT) regime to make it more effective and efficient. Key threats, vulnerabilities and priorities for disrupting and preventing illicit finance activities within the US financial system were identified in the 2020 Strategy. The Strategy was built upon the 2018 National Strategy and updates it for Combating Terrorist and Other Illicit Financing, pursuant to the Countering America’s Adversaries Through Sanctions Act of 2017 (CAATSA).

The 2020 Strategy represents a comprehensive effort by the Trump Administration to assess key 21st-century illicit finance challenges and identify solutions 50 years after the passage of the first AML/CFT law in the United States, the Bank Secrecy Act. The 2020 Strategy articulates increasing transparency and closing gaps in the U.S. AML/CFT legal framework; improving the efficiency and effectiveness of the U.S. AML/CFT regulatory and supervisory framework for financial institutions, and lastly enhancing current AML/CFT operational capabilities.  Financial institutions will find these documents helpful in informing their own risk assessments, and examiners will be able to use them in assessing whether AML/CFT compliance is tailored to the risks faced by their supervised entities. Other U.S. Government agencies, including law enforcement agencies and policymakers, will also find that the 2020 Strategy and 2018 National Risk Assessments inform a risk-based approach to their work that is flexible enough to address threats in real-time. The National Illicit Finance Strategy was prepared by the Office of Terrorist Financing and Financial Crimes, in consultation with the many agencies, bureaus, and departments of the federal government that also have roles in combating illicit finance.