By John Arvanitis, Senior Managing Director, Global Financial Crimes Compliance and Kari Trautvetter, Manager, Treliant
The Anti-Money Laundering Whistleblower Improvement Act (the Act) was included in the budget presented to US President Joe Biden by Congress on December 23, 2022. This provision covers a broad range of institutions spanning 26 categories, such as banks, foreign bank branches and agencies, broker-dealers, insurance companies, credit-card system operators, mutual funds, select casinos and travel agencies. The Act expands the scope of the law to encompass the reporting of financial-management rule violations by executive agencies, sanctions against foreign nations, and entities or individuals classified as enemies of the United States. The Act establishes a funding structure and minimum rewards for successful whistleblowers. These modifications raise the probability that employers engaging in financial activities, operating internationally in regions subject to US sanctions and/or having obligations to comply with the laws mentioned above will receive increased numbers of reports from employees claiming to be whistleblowers.
The Anti-Money Laundering Act of 2020 (AMLA) whistleblower provision seeks to introduce several important amendments that will bring financial institutions in line with other effective federal whistleblower programs, such as the False Claims Act,1 the U.S. Securities and Exchange Commission (SEC) whistleblower program2 and the Internal...
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