2022 Anti-Money Laundering and Sanctions Year in Review

In 2022, anti-money laundering ("AML") and sanctions controls were at the center of regulatory and enforcement activities in the United States and abroad. Globally, governments have continued to recognize the impact of AML legislation on the health and stability of their financial sector. In a continuing trend, digital assets remained a top enforcement priority in 2022, and authorities issued record-setting penalties in a number of high-profile cases. 

Following Russia's invasion of Ukraine in February 2022, lawmakers immediately sought to enact comprehensive sanctions packages with the goal of limiting Russia's ability to participate in the global economy. These sanctions frameworks continue to evolve as regulators confront emerging issues. By the end of 2022, the European Union had released its ninth legislative sanctions package, with a 10th following in early 2023. Legislators and regulators have maintained focus on the virtual currency industry, including by taking action against illicit actors who use digital assets to circumvent sanctions controls. 

This Year in Review explores these and other noteworthy legislative and enforcement developments related to AML and sanctions in 2022, considers the potential impact on financial institutions as a result of these developments, and explores the industry trends expected to continue throughout 2023.

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