To strengthen the enforcement of anti-money laundering (AML) laws and Bank Secrecy Act (BSA) regulations, Congress included in the Anti-Money Laundering Act of 2020 (AMLA) a robust whistleblower reward program. The AMLA whistleblower rewards program requires the Department of the Treasury (Treasury) to pay awards to whistleblowers who voluntarily provide original information leading to successful enforcement actions for AML violations.
Recently Congress strengthened the AML whistleblower rewards law by enacting the Anti-Money Laundering Whistleblower Improvement Act, which 1) establishes a minimum award of 10% of collected monetary sanctions; 2) creates an AML and counter-terrorism financing fund from which whistleblower awards can be paid (from sanctions collected in successful enforcement actions stemming from whistleblower disclosures); and 3) expands the AMLA whistleblower law to reward disclosures of sanctions violations, i.e., violations of the International Emergency Economic Powers Act, sections 5 and 12 of the Trading With the Enemy Act, or the Foreign Narcotics Kingpin Designation Act. Congress included the Anti-Money Laundering Whistleblower Improvement Act in the Consolidated Appropriations Act of 2023, which President Biden signed into law on December 23, 2022.
The AMLA whistleblower law will likely be a game changer in AML and sanctions enforcement and will strengthen national security by combating the illicit finance that is pivotal to the operation of...
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