Davis Polk AML/CFT head Dan Stipano was quoted in American Banker discussing the purpose of the Bank Secrecy and Corporate Transparency Acts. 

The article mentioned that the 9/11 attacks prompted Congress to revamp how U.S. banks detect money laundering and terrorist financing. However, some banking experts are now critical of the post-9/11 anti-money laundering regulatory framework, saying it has devolved into an expensive “box-checking” exercise.

“If you go back to the original purpose of the Bank Secrecy Act, which is to provide information and reports that are highly useful to law enforcement, criminal investigations, and tax investigations, that original purpose has been lost or de-emphasized at least, and the focus has tended to be more on technical compliance with rules, ” Dan said.

The article also noted that some banking experts believe the change to the current AML framework regarding shell companies could expose the country to security risks.

Discussing the decision to permanently end reporting requirements on beneficial ownership for U.S. companies and citizens under the Corporate Transparency Act, Dan explained, “The original design of the Corporate Transparency Act was to create this centralized, national registry of beneficial owners for the benefit of law enforcement. By making this change, the registry that’s left will be of very little value to law enforcement.”

“The 9/11 attacks marked a sea change in bank regulation,” American Banker (September 10, 2026) (subscription required)

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