Whistleblower advocates heralded the Anti-Money Laundering (AML) Whistleblower Improvement Act, which passed Congress in December 2022, as one of the most important anti-corruption laws ever passed. Now, as the Treasury Department and Financial Crimes Enforcement Network (FinCEN) draft regulations implementing the AML Whistleblower Program, advocates are calling on the agencies to ensure that the regulations are consistent with the United States’ global anti-corruption efforts.
In a new article in the Columbia Law School Blue Sky Blog, whistleblower attorney Stephen M. Kohn of Kohn, Kohn & Colapinto details the importance of developing regulations that harmonize the implementation of the AML Whistleblower Act with the transnational use of the law.
“Given the transnational reach of the AML Act’s whistleblower provisions, the global nature of money laundering, and the central role money laundering plays in enabling corruption to flourish, the AML whistleblower program is primed to play a central role in the United States’ global anti-corruption efforts,” writes Kohn. “Therefore, it is essential that FinCEN craft regulations that will ensure that whistleblowers have an incentive to report in a manner consistent with the needs and customs of international whistleblowers.”
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