In a cliff-hanger before the end of the 116th Congress, the National Defense Authorization Act was enacted into law with an array of provisions significantly revising U.S. anti-money laundering (AML) and countering the financing of terrorism (CFT) requirements.  The most consequential of these is long-sought standards requiring beneficial-ownership reporting that enhance the accuracy of bank know-your-customer (KYC) investigations and reduce associated compliance burden as well as risk.  However, the new law also extends the reach of U.S. law enforcement to any foreign bank doing correspondent business with a U.S. bank, raising legal and reputational risk despite questions about such a sweeping exterritorial application of one nation’s standards.