In January 2020, the U.S. Department of the Treasury issued its National Strategy for Combatting Terrorist and Other Illicit Financing (2020 Strategy). This document details the key priorities of the U.S. government regarding the enforcement of the Bank Secrecy Act (BSA) and its broader agenda on efforts related to anti-money laundering and the combating the financing of terrorism (AML/CFT). Marking the 50th anniversary of the BSA, the U.S. Treasury described the 2020 Strategy as identifying key threats, vulnerabilities, and priorities for disrupting and preventing illicit finance activities within and transiting the U.S. financial system, and providing a roadmap to modernize the AML/CFT regime.

The 2020 Strategy follows a year when in 2019 global enforcers imposed more than $8 billion in anti-money laundering fines. This figure doubles the amount of penalties meted out in 2018, which approached $4.27 billion. U.S. enforcement agencies and regulators were the most active, handing out 25 penalties totaling $2.29 billion. Of the world’s top 50 banks, 12 were hit with fines in 2019.