Did you know that Congress supersized the Anti-Money Laundering (“AML”) whistleblower program when it included the program in the AML Act of 2020 (“AMLA”)? Then, last month, it expanded the program with the AML Whistleblower Improvement Act (“Improvement Act”). Passed as part of the Consolidated Appropriations Act, 2023, the Improvement Act funds the relatively unknown whistleblower program and expands it beyond violations of the Bank Secrecy Act (“BSA”) to include violations of US economic sanctions laws. Through this expansion, the Improvement Act extends the whistleblower program to include not only financial institutions with BSA obligations, but also any company that is subject to US jurisdiction if it violates US economic sanctions laws. The 2020 AMLA’s sweeping revisions bring the AML whistleblower program in line with other established whistleblower regimes, including the False Claims Act and the Securities and Exchange Commission’s whistleblower program, which was established under the Dodd-Frank Act.
Treasury’s Financial Crimes Enforcement Network (“FinCEN”) and the Office of Foreign Assets Control (“OFAC”) are clearly entering a revitalized era of whistleblower initiated enforcement actions and you should know what that means for you.
The AMLA offers considerable protection from retaliation, covering people who report potential violations to someone within their organization with supervisory...
A slew of NYPD officers recounted on Sunday horror stories from their careers in which they say they were falsely accused of sexual misconduct and, despite being exonerated, had the allegations sh...