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CE Anti Money Laundering Legal

The course equips licensed attorneys with CE-level expertise in AML law, covering BSA/AML framework, gatekeeper duties, due diligence, suspicious activity reporting, and OFAC sanctions compliance, enabling risk-aware legal practice.

Who Should Take This

It is ideal for practicing attorneys, in-house counsel, and law firm partners who regularly handle corporate, financial, or real‑estate transactions and need to fulfill continuing legal education requirements while mastering AML risk identification and client advisory responsibilities. They also seek to align their practice with evolving regulatory expectations and avoid costly sanctions.

What's Included in AccelaStudy® AI

Adaptive Knowledge Graph
Practice Questions
Lesson Modules
Console Simulator Labs
Exam Tips & Strategy
20 Activity Formats

Course Outline

63 learning goals
1 BSA/AML Regulatory Framework
2 topics

Bank Secrecy Act fundamentals

  • Recognize the key provisions of the Bank Secrecy Act including currency transaction reporting, recordkeeping requirements, and the definition of financial institution.
  • Comprehend the evolution of BSA/AML regulations from the original 1970 BSA through the USA PATRIOT Act, AML Act of 2020, and Corporate Transparency Act.
  • Analyze whether a specific entity or transaction triggers BSA reporting requirements including CTR filing thresholds and structuring prohibitions.
  • Recognize the role of FinCEN as the primary regulatory authority for BSA/AML enforcement and its relationship to other federal and state regulators.

AML program requirements

  • Comprehend the five pillars of an effective AML compliance program including internal controls, compliance officer designation, training, independent testing, and CDD procedures.
  • Analyze whether an organization's AML compliance program satisfies regulatory requirements and identify deficiencies that could result in enforcement action.
  • Synthesize an AML compliance program tailored to the risk profile of a specific financial institution including policies, procedures, training curriculum, and testing schedule.
2 Attorney Gatekeeper Role
2 topics

Lawyers as gatekeepers against money laundering

  • Recognize the international gatekeeper standards for attorneys under FATF Recommendations 22 and 23 and their applicability to US legal practice.
  • Comprehend the tension between attorney-client privilege, duty of confidentiality, and AML reporting obligations that creates unique compliance challenges for lawyers.
  • Analyze scenarios where an attorney discovers potential money laundering activity by a client and determine the ethical and legal obligations including withdrawal considerations.
  • Recognize the ABA voluntary good practices guidance for lawyers to detect and prevent money laundering through client engagement and matter management.

Law firm AML risk areas

  • Comprehend the specific money laundering risks associated with lawyer trust accounts including IOLTA account misuse, layering through escrow transactions, and commingling.
  • Analyze high-risk practice areas for money laundering exposure including real estate transactions, corporate formations, trust and estate planning, and international transactions.
  • Synthesize a risk-based AML compliance framework for a law firm addressing client intake procedures, matter screening, trust account monitoring, and suspicious activity protocols.
3 Customer Due Diligence and Enhanced Due Diligence
2 topics

CDD requirements and procedures

  • Recognize the four core elements of customer due diligence under the FinCEN CDD Rule including customer identification, beneficial ownership, risk profile, and ongoing monitoring.
  • Comprehend the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act including acceptable identification documents and verification methods.
  • Analyze a customer onboarding scenario to determine whether CDD procedures have been properly followed and identify additional due diligence requirements.
  • Recognize the triggers that escalate standard CDD to enhanced due diligence including PEPs, high-risk jurisdictions, complex ownership structures, and unusual transaction patterns.

Enhanced due diligence and ongoing monitoring

  • Comprehend the enhanced due diligence procedures required for high-risk customers including source of funds verification, senior management approval, and increased monitoring frequency.
  • Analyze whether a customer's risk profile warrants EDD and determine the appropriate level of additional due diligence measures.
  • Synthesize a risk-based customer due diligence program that incorporates tiered CDD/EDD procedures, periodic review schedules, and escalation protocols.
4 Suspicious Activity Identification and Reporting
2 topics

Red flags and suspicious activity indicators

  • Recognize common red flags for money laundering including structuring, unusual cash activity, rapid movement of funds, shell company usage, and geographic risk indicators.
  • Comprehend the behavioral indicators of money laundering including customer reluctance to provide information, inconsistent transaction patterns, and third-party funding anomalies.
  • Analyze transaction patterns and customer behavior to determine whether suspicious activity indicators are present and whether further investigation is warranted.
  • Recognize trade-based money laundering techniques including over-invoicing, under-invoicing, phantom shipments, and multiple invoicing of the same goods.

SAR filing obligations and procedures

  • Comprehend the Suspicious Activity Report filing requirements including threshold amounts, filing timelines, narrative content standards, and continuing activity reporting.
  • Recognize the confidentiality protections and safe harbor provisions for SAR filers including the prohibition on tipping off subjects of SARs.
  • Analyze a suspicious activity scenario to determine whether a SAR filing obligation exists and draft the key elements of an effective SAR narrative.
  • Synthesize a suspicious activity monitoring and reporting program that integrates automated transaction monitoring, alert investigation procedures, and quality assurance for SAR filings.
5 OFAC Sanctions Compliance
2 topics

OFAC sanctions framework

  • Recognize the structure of the OFAC sanctions regime including the SDN List, sectoral sanctions, country-based sanctions, and secondary sanctions programs.
  • Comprehend the legal obligations of US persons under OFAC sanctions including the strict liability standard, blocking requirements, and specific license provisions.
  • Analyze a cross-border transaction to determine whether OFAC sanctions apply and identify required screening, blocking, or licensing actions.
  • Comprehend the OFAC enforcement framework including civil penalties, voluntary self-disclosure benefits, and the factors considered in penalty calculations.

Sanctions compliance programs

  • Recognize the five essential components of an OFAC compliance program as outlined in OFAC's Framework for Compliance Commitments.
  • Analyze a sanctions screening failure to determine the root cause and recommend corrective actions including enhanced screening protocols and interdiction procedures.
  • Synthesize a comprehensive sanctions compliance program addressing screening technology, alert management, escalation procedures, and recordkeeping requirements.
6 Beneficial Ownership and Corporate Transparency
2 topics

Beneficial ownership requirements

  • Recognize the beneficial ownership reporting requirements under the Corporate Transparency Act including reporting companies, beneficial owners, and company applicants.
  • Comprehend the FinCEN beneficial ownership information reporting rule including filing deadlines, required information, exemptions for reporting companies, and update obligations.
  • Analyze a corporate structure to determine which entities are reporting companies, identify all beneficial owners, and determine applicable exemptions.
  • Recognize the penalties for non-compliance with beneficial ownership reporting including civil and criminal sanctions for willful violations.

Shell companies and layered ownership

  • Comprehend how shell companies, nominees, and layered corporate structures are used to obscure beneficial ownership and facilitate money laundering.
  • Analyze a complex multi-entity corporate structure to identify concealed beneficial ownership and assess money laundering risk.
  • Synthesize due diligence procedures for law firms forming corporate entities that address beneficial ownership verification and AML risk mitigation.
7 Real Estate AML
1 topic

Real estate money laundering risks

  • Recognize the money laundering vulnerabilities in real estate transactions including all-cash purchases, use of LLCs, nominee buyers, and rapid property flipping.
  • Comprehend the FinCEN Geographic Targeting Orders for real estate and the proposed rulemaking extending AML requirements to real estate professionals.
  • Analyze a real estate transaction to identify money laundering red flags and determine the attorney's due diligence and reporting obligations.
  • Synthesize AML due diligence procedures for real estate transactions that address buyer verification, source of funds confirmation, and escalation protocols.
8 Cryptocurrency and Virtual Asset AML
2 topics

Virtual asset AML regulatory framework

  • Recognize the regulatory classification of virtual assets and virtual asset service providers under FinCEN guidance and FATF standards.
  • Comprehend the AML obligations of cryptocurrency exchanges, DeFi platforms, and NFT marketplaces including registration, CDD, transaction monitoring, and SAR filing.
  • Recognize the money laundering typologies specific to virtual assets including mixing services, chain hopping, privacy coins, and peer-to-peer exchanges.
  • Analyze a cryptocurrency transaction pattern to identify potential money laundering indicators and determine applicable BSA/AML reporting obligations.

Blockchain analytics and enforcement

  • Comprehend how blockchain analytics tools trace cryptocurrency transactions and their use in AML investigations by law enforcement and compliance teams.
  • Analyze the legal implications of cryptocurrency seizure and forfeiture proceedings for attorneys representing clients in digital asset enforcement actions.
9 AML Enforcement and Penalties
1 topic

Criminal and civil enforcement

  • Recognize the criminal penalties for money laundering under 18 USC 1956 and 1957 including elements of the offenses, predicate crimes, and sentencing guidelines.
  • Comprehend the civil enforcement tools available to regulators including consent orders, civil money penalties, cease and desist orders, and deferred prosecution agreements.
  • Analyze an AML enforcement action to identify the violations, assess the adequacy of the compliance program, and evaluate potential remediation strategies.
  • Synthesize a remediation plan for an organization facing AML enforcement action addressing program enhancements, lookback reviews, and regulatory engagement strategy.
10 International AML Standards and Cooperation
2 topics

FATF and international frameworks

  • Recognize the role of the Financial Action Task Force and its 40 Recommendations as the global standard for AML and counter-terrorism financing.
  • Comprehend the mutual evaluation process and its impact on countries identified as high-risk or non-cooperative jurisdictions by the FATF grey and black lists.
  • Analyze how international AML standards impact US legal practice including correspondent banking relationships, cross-border investigations, and mutual legal assistance treaties.

Counter-terrorism financing

  • Recognize the legal framework for combating terrorism financing including the material support statutes, IEEPA, and designated terrorist organization lists.
  • Comprehend how terrorism financing differs from traditional money laundering in terms of sources, amounts, methods, and detection challenges.
  • Analyze a transaction scenario to distinguish between money laundering and terrorism financing indicators and determine appropriate reporting and compliance responses.

Scope

Included Topics

  • Bank Secrecy Act and AML regulations including CTR filing, recordkeeping, and the evolution through USA PATRIOT Act, AML Act of 2020, and Corporate Transparency Act.
  • Attorney gatekeeper role in AML compliance including FATF standards, ABA voluntary good practices, privilege tensions, and law firm risk areas.
  • Customer due diligence and enhanced due diligence including CIP requirements, beneficial ownership verification, risk-based procedures, and ongoing monitoring.
  • Suspicious activity identification and SAR filing including red flags, behavioral indicators, filing obligations, confidentiality protections, and narrative standards.
  • OFAC sanctions compliance including SDN screening, blocking requirements, licensing, enforcement penalties, and compliance program frameworks.
  • Beneficial ownership and corporate transparency including CTA reporting requirements, shell company identification, and layered ownership analysis.
  • Real estate money laundering risks including all-cash transactions, Geographic Targeting Orders, and attorney due diligence obligations.
  • Cryptocurrency and virtual asset AML including VASP regulation, blockchain analytics, money laundering typologies, and enforcement actions.
  • AML enforcement and penalties including criminal statutes, civil enforcement tools, remediation strategies, and deferred prosecution agreements.
  • International AML standards including FATF Recommendations, mutual evaluations, counter-terrorism financing, and cross-border cooperation.

Not Covered

  • Technical details of transaction monitoring software implementation or algorithm design.
  • Detailed banking operations or financial institution management unrelated to AML compliance.
  • Tax evasion and fraud schemes beyond their intersection with money laundering.
  • Detailed law enforcement investigation techniques or intelligence gathering methods.
  • White-collar criminal defense trial strategy beyond its intersection with AML compliance.

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