News & Analysis as of

Whistleblowers Bank Secrecy Act

Womble Bond Dickinson

2025 National Health Care Fraud Takedown Sets Record as Largest in U.S. History, Charging 324 Defendants for Over $14.6 Billion in...

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On June 30, 2025, the Department of Justice announced the results of its 2025 National Health Care Fraud Takedown (“2025 Takedown”). ...more

Oberheiden P.C.

10 Important Facts About FinCEN’s Whistleblower Program

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The Financial Crimes Enforcement Network (FinCEN) is one of a handful of federal authorities that have adopted whistleblower programs focused on facilitating enforcement in hard-to-target areas. While FinCEN focuses its...more

Holland & Hart LLP

Key Compliance Takeaways for Companies from the DOJ's New Corporate Whistleblower Program

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On August 1, 2024, the U.S. Department of Justice (“DOJ”) announced its new “Corporate Whistleblower Awards Pilot Program” (“DOJ Program”), a three-year initiative managed by DOJ’s Money Laundering and Asset Recovery Section....more

Ballard Spahr LLP

DOJ Unveils Corporate Whistleblower Awards Pilot Program – With Implications for Financial Institutions and AML/CFT Compliance...

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On August 1, 2024, the Department of Justice launched its Corporate Whistleblower Awards Pilot Program (the “Pilot Program”). Under this 3-year initiative managed by DOJ’s Criminal Division, a whistleblower may be eligible...more

Bracewell LLP

DOJ Spotlights Voluntary Self Disclosure in M&A as it Adapts to New National Security Threats

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The past few months have seen numerous high-profile enforcement actions highlighting an increasing trend, what Deputy Attorney General Lisa Monaco called “the biggest shift in corporate criminal enforcement that I’ve seen...more

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - October 2023

The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...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

K2 Integrity

DOJ, BIS, and OFAC Issue Tri-Seal Compliance Note Consolidating Information Regarding Voluntary Self-Disclosure Policies

K2 Integrity on

The U.S. Department of Justice (DOJ), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published their second Tri-Seal...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

Venable LLP

Honesty is Good for Your Bottom Line: Commerce, Treasury, and DOJ Tout the Benefits of Voluntary Self Disclosure in Tri-Seal...

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Voluntary self-disclosure is a valuable remediation measure for companies who identify their own potential violations of U.S. sanctions, export controls, and other national security laws....more

Carlton Fields

AML Whistleblowers Now Have More Appetizing Options

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On December 29, 2022, President Biden signed into law the Anti-Money Laundering Whistleblower Improvement Act. The law contains important enhancements to the Anti-Money Laundering Act, which created a whistleblower program...more

Pietragallo Gordon Alfano Bosick & Raspanti,...

SEC’s Historic $279 Million Whistleblower Bounty Makes For Three Consecutive Years Of Record-Breaking Awards

On May 5, 2023, the Securities and Exchange Commission (“SEC”) announced that it had awarded a single whistleblower $279 million. This is the largest award made under the SEC’s Whistleblower Program by a long shot – more than...more

Torres Trade Law, PLLC

New Anti-Money Laundering Whistleblower Law Makes Economic Sanctions Violations Reportable

To more effectively counter transnational corruption and economic sanctions evasion, recent changes to the U.S. anti-money laundering (“AML”) whistleblower regime expand and reinforce whistleblower protections and rewards in...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

Goodwin

Stress Test Scenarios Released for 2022

Goodwin on

In This Issue. The Federal Reserve Board of Governors (Federal Reserve), the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) released stress test scenarios to assess...more

Perkins Coie

AMLA 2020 Series Part 2: New Bank Secrecy Act Whistleblower Provisions

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On New Year’s Day 2021, Congress passed the Anti-Money Laundering Act of 2020 (AMLA 2020). As we reported last April, the AMLA 2020 included sweeping reforms aimed at strengthening protections against money laundering,...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

The Volkov Law Group

Whistleblower Protections under the Anti-Money Laundering Act of 2020

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When Congress overrode former President Donald J. Trump’s veto of the 2021 National Defense Authorization Act (“NDAA”) in January of this year, it simultaneously enacted the Anti-Money Laundering Act of 2020 (“AMLA”) into...more

Ballard Spahr LLP

The New BSA Whistleblower Law: What You Need to Know

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Today’s episode features a discussion of the new whistleblower provisions in the Anti-Money Laundering Act of 2020. We’ll discuss the types of businesses covered, who can be a whistleblower under the Act, the increased...more

King & Spalding

Tokyo Dispute Resolution & Crisis Management Newsletter - February 2021 - U.S. & Americas Enforcement Review 2020

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As 2020 drew to a close, enforcement authorities throughout the United States and the Americas continued to investigate fraud, corruption, and other misconduct across the region. In this newsletter, we highlight some...more

Vinson & Elkins LLP

OSHA’s Expanding Horizons: Whistleblower Protections For Money Laundering And Criminal Antitrust Violations

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At this point, most employers probably know that the Occupational Safety and Health Administration (“OSHA”) is charged with investigating far more than workplace safety. Indeed, OSHA has a robust Whistleblower Protection...more

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