The Anti-Money Laundering Act (AMLA) of 2020 is the most significant piece of anti-money laundering (AML) legislation since the enactment of the USA PATRIOT Act more than 20 years ago. AMLA, signed into law last January as part of the National Defense Authorization Act for Fiscal Year 2021, establishes enhanced whistleblower protections for informants and requires the U.S. Department of the Treasury’s (Treasury) Financial Crimes Enforcement Network (FinCEN) to modernize its regulations to address evolving risks to the security of the U.S. financial system.

One of AMLA’s most significant provisions is the expanded whistleblower protections for financial sector employees for reporting potential violations of the Bank Secrecy Act (BSA) and the federal money laundering laws. See 31 U.S.C. §5323. Recognizing the success of other whistleblower programs, AMLA greatly expands upon the BSA’s prior whistleblower program, for which implementing regulations were never promulgated and which capped awards.

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