News & Analysis as of

Whistleblowers FinCEN Anti-Money Laundering

Kohn, Kohn & Colapinto LLP

FinCEN Head Praises New AML Whistleblower Program

The passage of the Anti-Money Laundering (AML) Whistleblower Improvement Act in December 2022 was heralded by whistleblower advocates as a major development which would transform the ability of the U.S. to crack-down on money...more

Kohn, Kohn & Colapinto LLP

FinCEN’s New Rules for Reporting Beneficial Owners Create Opportunity for Whistleblowers

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) is enacting new rules for January 1, 2024, requiring companies to report their beneficial owners to FinCEN. Violations of these new...more

Akin Gump Strauss Hauer & Feld LLP

7 Enforcement Predictions For US Export Controls, Sanctions

Within the trade bar there is cautiousness, curiosity and skepticism at the numerous pronouncements signaling greater enforcement of export controls and sanctions by the Bureau of Industry and Security, the Office of Foreign...more

Ballard Spahr LLP

New FinCEN Director Addresses Key Topics in BSA/AML

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The new Director of FinCEN, Andrea Gacki, addressed several key topics on October 3, 2023 at the Association of Certified Anti-Money Laundering Specialists (“ACAMS”) conference in Las Vegas, Nevada. Specifically, Director...more

Jones Day

Federal Agencies Highlight Benefits of Self-Disclosure, Emphasize Enforcement of Trade Violations in Tri-Seal Compliance Note

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In a coordinated announcement, federal agencies stress the benefits of voluntarily disclosing potential trade violations while emphasizing increased enforcement....more

Ballard Spahr LLP

“Tri-Seal” Compliance Notice: U.S. Authorities Release Joint Guidance on Voluntary Self-Disclosure of Potential Sanctions and...

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On July 26, the Department of Commerce, the Department of the Treasury, and the Department of Justice released a joint compliance notice (the “Compliance Notice”) updating and summarizing each agency’s position regarding the...more

Fenwick & West LLP

New Official Guidance on Voluntary Self-Disclosure of Trade Control Violations

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On July 26, 2023, the U.S. Department of Commerce, Bureau of Industry and Security (BIS), the U.S. Department of the Treasury Office of Foreign Asset Control (OFAC) and the U.S. Department of Justice (DOJ) released joint...more

Kohn, Kohn & Colapinto LLP

Treasury and FinCEN are Taking the New AML Law Seriously

When President Biden signed the Anti-Money Laundering (AML) Whistleblower Improvement Act on December 29th, 2022, the Treasury Department had its work cut out for them. In the shadow of the highly successful Securities and...more

Pietragallo Gordon Alfano Bosick & Raspanti,...

Congress Fixes Major Hole In Treasury’s Nascent Whistleblower Program While Expanding Its Scope To Sanctions Evaders

Takeaways: •The Treasury Whistleblower Program now provides for guaranteed awards of 10% to 30% of the government recovery in covered actions- •The Treasury Whistleblower Program has been expanded to include not just tips...more

Ballard Spahr LLP

BSA Whistleblower Provision Gains Teeth

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As we have blogged (here, here, here, here and here), the Anti-Money Laundering Act of 2020 (“the AMLA”) amended the Bank Secrecy Act (“BSA”) to expand whistleblower incentives and strengthen whistleblower protections. At a...more

Ballard Spahr LLP

New AML Whistleblower Program Highlighted by FinCEN Acting Director

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Acting Director Suggests that Financial Institutions Should “Welcome” the Program - Himamauli Das, the Acting Director of the Financial Crimes Enforcement Network (“FinCEN”), spoke about the Anti-Money Laundering Act of...more

King & Spalding

FinCEN Issues Anti-Money Laundering and Countering the Financing of Terrorism Priorities

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FinCEN announces eight areas of focus and advises preparation for issuance of new regulations - On June 30, 2021, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued the first...more

King & Spalding

FinCEN’s New Whistleblower Program: Global Implications

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Modernizing FinCEN’s Whistleblower Program Under the Anti-Money Laundering Act of 2020 - INTRODUCTION - Reporting on multiple international money-laundering schemes last year brought public focus to the anti-money...more

Dechert LLP

Congress Enacts Significant Changes to the U.S. Anti-Money Laundering Regime

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The Anti-Money Laundering Act of 2020 (AML Act), enacted on January 1, 2021 as part of the National Defense Authorization Act for Fiscal Year of 2021 (NDAA), makes several significant changes to U.S. anti-money laundering...more

Law Matters

Loopholes Doom Money Laundering Anti-Retaliation Law

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A perspective from leading whistleblower attorney Stephen M. Kohn...more

Buchalter

Treasury’s New Bank Secrecy Act Whistleblower Program

Buchalter on

In perhaps the last major legislative action under this presidential administration, on New Year’s Day 2021, Congress passed—over President Trump’s veto—what could be the most significant anti-money laundering (AML) statute...more

Lowenstein Sandler LLP

Anti-Money Laundering Act Requires Fresh Look At Compliance

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The Anti-Money Laundering Act of 2020 took effect on Jan. 1 and is the most significant anti-money laundering statute since the USA Patriot Act was passed after the terrorist attacks of 9/11. Its primary purpose was to update...more

BakerHostetler

The Anti-Money Laundering Act of 2020: What Companies Need to Know

BakerHostetler on

On January 1, 2021, Congress overrode President Trump’s veto of the National Defense Authorization Act for Fiscal Year 2021, an omnibus bill that includes the Anti-Money Laundering Act of 2020 (the “AMLA”). The AMLA...more

K&L Gates LLP

More Tools for AML Enforcement and More to Come: Key Considerations from the 2020 Anti-Money Laundering Act and the Corporate...

K&L Gates LLP on

On 1 January 2021, Congress overrode President Trump’s veto of the National Defense Authorization Act (the NDAA). As part of the NDAA, Congress included long-considered provisions with the potential to revolutionize...more

Holland & Knight LLP

Key Provisions of the Anti-Money Laundering Act of 2020

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The Anti-Money Laundering Act of 2020 (AMLA 2020) became law on Jan. 2, 2020, when Congress overrode President Donald Trump's veto of the National Defense Authorization Act. AMLA 2020 is the most consequential anti-money...more

Miles & Stockbridge P.C.

Top 5 Changes To Anti-Money Laundering Requirements

On January 1, 2021, the National Defense Authorization Act became law after Congress overrode the President’s veto. As highlighted below, Congress enacted a variety of key provisions that create significant and sweeping...more

Thomas Fox - Compliance Evangelist

Major Changes in AML Compliance and Enforcement – Whistleblower Provisions

2020 was a most significant year in anti-corruption enforcement, from Airbus SE to Goldman Sachs Group, Inc., and numerous matters in between. Further, there were two significant pieces of information from the US government...more

Pillsbury Winthrop Shaw Pittman LLP

Legislative Reform Will Reinvent the US Anti-Money Laundering Regulatory Landscape

New federal requirements in the annual national defense budget reauthorization effectively will end anonymous U.S. shell companies by requiring businesses to disclose 25 percent owners and control persons to a newly created...more

Vinson & Elkins LLP

Congress Expands The Scope Of Anti-Money Laundering Rules—Disclosing Beneficial Owners Now Required – UPDATED January 2020

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Update: On January 1, 2021, the Senate voted to override President Trump’s veto of the National Defense Authorization Act for Fiscal Year 2021 (“NDAA”). The House had already voted to override the veto. The NDAA and its...more

King & Spalding

New BSA/AML Regime Promises Sweeping Changes

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As we wrote over the summer, Congress has passed a bill that will require certain corporations and limited liability companies (“LLCs”) to report information on their beneficial owners to the U.S. Treasury Department’s...more

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