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Implementation of the AMLA and the CTA by Financial Institutions: A Podcast


With Guest Speaker Matthew Haslinger of M&T Bank

We are extremely pleased to offer a podcast (here) on the legal and logistical issues facing financial institutions as they implement the regulations issued by the Financial Crimes Enforcement Network (FinCEN) pursuant to the Anti-Money Laundering Act of 2020 (AMLA) and the Corporate Transparency Act (CTA), and as they try to anticipate future related regulations.

We are very fortunate to have Matthew Haslinger as our guest speaker. Mr. Haslinger serves as the Chief BSA/AML/OFAC Officer for M&T Bank.  He began his career as a federal prosecutor in the Bank Integrity Unit of the U.S. Department of Justice’s Money Laundering and Asset Recovery Section, where he investigated and prosecuted complex national and international money laundering and sanctions-related matters.  Mr. Haslinger then moved to M&T Bank, where he initially headed the Financial Investigations Unit and was responsible for day-to-day operations and strategic decision-making relating to enterprise-wide transaction monitoring, customer investigations and suspicious activity report filing for the bank.  In July 2020, he became the Chief BSA/AML Officer.  In this role, Mr. Haslinger is now responsible for oversight, implementation, and strategic direction of the enterprise-wide programs for Bank Secrecy Act (BSA), Anti-Money Laundering (AML) and Governmental Sanctions compliance.

In this podcast, we dive into the historic changes made by the AMLA and the CTA. After reviewing how the AMLA expands the BSA’s goals, we look at some of the AMLA provisions which have the most impact on BSA compliance, including the AMLA’s emphasis on information sharing, FinCEN’s “national priorities” and the value of threat pattern and trend information to bank compliance efforts, and the AMLA’s expansion of the U.S. government’s authority to subpoena information from foreign financial institutions that maintain correspondent banking relationships with U.S. banks. We also review the CTA’s new beneficial ownership reporting requirements and discuss how they may interact with existing customer due diligence (CDD) requirements and the need to align CTA and CDD regulations.

This podcast is the latest episode in Ballard Spahr’s Consumer Financial Monitor Podcast series — a weekly podcast focusing on the issues that matter most, from new product development and emerging technologies to regulatory compliance and enforcement and the ramifications of private litigation. We hope that you enjoy the podcast.

If you would like to remain updated on these issues, please click here to subscribe to Money Laundering Watch. To learn more about Ballard Spahr’s Anti-Money Laundering Team, please click here.  To visit Ballard Spahr’s Consumer Financial Monitor blog, please click here.


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