In this report, we analyze today’s second Senate Banking hearing on modernizing the U.S. anti-money laundering (AML) framework.  It evidenced continued apprehension about details despite bipartisan agreement on broad reform principles.  Although Chairman Crapo (R-ID) and Ranking Member Brown (D-OH) agreed that legislation should address beneficial-ownership disclosure requirements, Sen. Brown expressed reservations about possible privacy problems and continued to push back on increasing SAR thresholds.  There was, though, broad agreement by senators from both parties that cryptocurrency is being used by criminal actors and rogue states, although Treasury Under-Secretary Mandelker emphasized that SAR reporting is already required in this area.  When pressed for broad AML-legislative recommendations, she emphasized the need for care and, when pressed for a timeline, said that recommendations should be ready within six months.  If Congress awaits these, as seems likely, then statutory change in this Congress is at best uncertain.

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