On New Year’s Day 2021, Congress passed the Anti-Money Laundering Act of 2020 (AMLA 2020). The AMLA 2020 included sweeping reforms aimed at strengthening protections against money laundering, terrorism financing, and other illegal activities.

In this article, we examine two new criminal penalties established by the AMLA 2020. In a nutshell, these penalties prohibit concealing or falsifying information related to ownership or control of funds in transactions involving senior foreign political figures and entities designated to be of primary money laundering concern. This is a potentially significant new tool providing for criminal prosecution targeting a broad swath of intermediaries who may be involved in facilitating transactions involving senior foreign political officials, including brokers, nominees, lawyers and any other person or entity that may communicate with a financial institution in the course of a transaction falling under these provisions.