Over the course of 2020, three major themes emerged from actions by FinCEN. First, FinCEN signaled its receptiveness to potentially significant modifications to the anti-money laundering/countering the financing of terrorism (“AML/CFT”) regime. These efforts included publication of an Advance Notice of Proposed Rulemaking (“ANPRM”) intended to modernize aspects of the regime and provide financial institutions with greater flexibility in allocating resources, and a notice of proposed rulemaking (“NPRM”) that would close AML regulatory gaps for convertible virtual currencies (“CVCs”) and digital assets with legal tender status (“LTDAs”). Second, FinCEN showed a willingness to clarify important aspects of the AML/CFT regime by issuing guidance in areas such as enforcement, customer due diligence (“CDD”) and customer identification program (“CIP”) requirements. Third, FinCEN showed increased diligence in advising financial institutions and the public of the evolving threats of illicit finance. The majority of the 2020 advisories focused on financial crime associated with the COVID-19 pandemic. FinCEN also issued a supplement to its 2014 advisory on human trafficking and related activity and an advisory on ransomware and the use of the financial system to facilitate ransom payments. Finally, FinCEN brought two enforcement actions against individuals, suggesting that individual accountability for BSA/AML failures continues to be a priority.