Anti-Money Laundering compliance programs
Anti-money laundering compliance in Defense and Government Contracting carries obligations that go beyond standard Bank Secrecy Act baselines. The Financial Crimes Enforcement Network and the Defense Contract Audit Agency have both signaled heightened scrutiny of contractor payment flows, foreign subcontractor arrangements, and beneficial ownership disclosures under the Corporate Transparency Act's final rule. Compliance teams in this sector are currently working to reconcile FinCEN's beneficial ownership reporting requirements with existing contractor disclosure obligations under the Federal Acquisition Regulation.
Watch
- Corporate Transparency Act beneficial ownership deadlines for government contractor entities
- FinCEN proposed rules expanding AML program requirements to non-bank financial intermediaries
- DCAA audit focus on foreign subcontractor payment traceability in cost-reimbursement contracts
- Treasury OFAC enforcement actions involving defense-adjacent sectors and sanctions evasion typologies
Recent material activity in Defense & Government Contracting
Active monitoring in place across Defense & Government Contracting. Material developments related to anti-money laundering compliance programs will appear here as they are published.