2024 U.S. anti-money laundering (AML) Regulatory Roundup
2024 has been a pivotal year for U.S. anti-money laundering (AML) regulations.
This year was marked by final rules that reshape financial compliance landscapes, and proposed changes that promise to further tighten regulations.
Rules finalized in 2024
- Residential real estate rule
- Registered investment adviser and exempt reporting adviser rule
Proposed changes ahead
- Customer Identification Program (CIP) for RIAs/ERAs
- AML/CFT program modernization
- Recordkeeping for custodial accounts
Who will feel the impact?
- Certain parties to non-financed residential real estate transfers
- Registered investment advisers (RIA)
- Exempt reporting advisers (ERA)
- FDIC- insured depository institutions and potentially third-party non-bank companies (e.g. payment providers & fintechs)
Notable Implications
- RIA/ERA rule extends to certain “foreign located IAs”
- Only one “reporting person” for each reportable real estate transfer
- Proposed CIP requirements are generally consistent with the CIP requirements for brokers or dealers and mutual funds
- Real estate transfers resulting from death or divorce are exempt from rule requirements
- AML/CFT programs must include a risk assessment process
- With some additional requirements, an IDI could maintain the records through an arrangement with a third-party
Let’s solve it together
Amidst these regulatory shifts, technology plays a pivotal role and it is imperative that institutions and firms find the right mix of technology to ensure effective risk management and compliance.
- AI-driven transaction monitoring
- Flexible & adaptive risk assessment tools
- Entity resolution & network analysis
- Generative AI & copilots
- AI-powered holistic case management
Stay ahead of financial criminals and ensure compliance with evolving AML regulations worldwide. SymphonyAI delivers an end-to-end suite of AML, sanctions, and KYC compliance and risk management solutions.
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Elizabeth has spent more than 20 years tackling money laundering (ML) and financial crime. At SymphonyAI she drives the strategy and innovation that delivers transformational compliance solutions. Prior to SymphonyAI she worked within the U.S. intelligence and law enforcement communities. As a Senior Intelligence Analyst with the U.S. Department of the Treasury, she drove U.S. policy and enforcement actions and supported U.S. officials and policymakers, including at OFAC and FinCEN, on ML threats and sanctions initiatives. She also served as Treasury’s first Intelligence Liaison and Senior Advisor to DEA’s Special Operations Division, spearheading large-scale ML investigations and intelligence collection initiatives, training law enforcement agents and analysts, and promoting collaboration between Treasury and U.S. and foreign law enforcement. In the private sector, Elizabeth also worked within financial institutions and consulting managing investigations teams, developing risk management strategies for complex products and services, and designing institutional AML programs and controls. Elizabeth also teaches AML and sanctions courses at the university level.