The Impact of the AMLA on Anti-Corruption Compliance and Enforcement
Bribe, Swindle or Steal
Alexandra Addison-Wrage of TRACE International
4.9 • 582 Ratings
🗓️ 6 April 2022
⏱️ 15 minutes
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| 0:00.0 | Welcome back to the podcast, Bride, Swindle, or Steel. |
| 0:10.1 | I'm Alexandra Ragi, and for today's podcast, we are listening in on Kara Brockmeier's presentation at the Trace Forum. |
| 0:16.8 | Kara is known to most of you. |
| 0:18.2 | She is a partner with Debovoise and the former chief of the FCPA unit at the SEC. |
| 0:23.6 | Here's Kara. |
| 0:24.7 | What I want to focus on is some of the provisions in this act that I think are going to have a significant impact on the government's ability to investigate anti-corruption matters. |
| 0:34.2 | And by extension, are going to have an impact on what companies need to think about when |
| 0:38.2 | they're facing potential investigation. Just a little bit of background. The Any Money Laundering Act of |
| 0:44.2 | 2020, the AMLA, was passed as part of the NDAA, which I didn't know what that stood for until |
| 0:50.2 | it passed. It's the National Defense Authorization Act, which you probably have heard a lot about |
| 0:55.3 | because in addition to funding the military and a bunch of other things, from an anti-corruption |
| 1:00.3 | standpoint and from an SEC enforcement standpoint, in particular, it had all kinds of goodies |
| 1:05.3 | baked into it. One of the things that was in there was the AMLA. Although it was not directed specifically at |
| 1:12.3 | anti-corruption because it is an anti-money laundering statute, it contains the most significant |
| 1:16.8 | changes to any money laundering and counterterrorism financing since the Patriot Act was passed |
| 1:23.5 | in 2001. And it is going to have broad implications, not just for financial institutions, |
| 1:29.5 | which are obviously most clearly in the crosshairs of the Act, but also for a broad swath |
| 1:37.1 | of companies because of the provisions regarding some of the things that we're going to talk |
| 1:42.3 | about today, beneficial ownership, |
| 1:50.8 | AML reporting obligations, and the U.S. government's ability to get information from foreign banks. |
| 1:58.1 | A lot of these powers are not only useful in AML cases, but for prosecutors are going to give them a real additional significant ability to trace payments internationally. |
| 2:05.6 | It's a considerable expansion of the toolbox that the government has to address AML and anti-corruption. |
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