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Whistleblower award programs are becoming more prevalent and incentivizing employees to report possible violations of law to the government. The Anti-Money Laundering Act of 2020 (“AML Act”), which was the most significant overhaul of the Bank Secrecy Act and related anti-money laundering laws since the USA PATRIOT Act of 2001, reestablished the AML whistleblower program to bring it closer in line with the SEC’s whistleblower program. Recently, to further incentivize potential whistleblowers, Congress passed the Anti-Money Laundering Whistleblower Improvement Act, which, among other reforms, established minimum awards for whistleblowers and added sanctions violations as reportable items under the program.
Using the SEC’s whistleblower program as an exemplar—in the 11 years since inception of the SEC’s whistleblower program, the SEC has received almost 65,000 whistleblower tips from individuals in the U.S. and 133 foreign countries, awarded more than $1.3 billion in awards, and fined companies and individuals in excess of $6.3 billion based on information from whistleblowers—this Briefing will discuss how whistleblower programs work, the significance of the recent AML whistleblower program enhancements, and what financial institutions need to know when revisiting their whistleblower programs in light of the reforms or responding to whistleblower investigations.
We invite you to join Arnold & Porter securities enforcement partner Kathleen Reilly , financial services partner Kevin M. Toomey and securities enforcement partner Jane Norberg (former Chief of the Office of the Whistleblower at the SEC) in a presentation where they will discuss:
- Overview of the AML whistleblower program established by the AML Act - 10 minutes
- Recently passed enhancements to components of the AML whistleblower program - 10 minutes
- Comparisons with and lessons learned from the SEC whistleblower program - 20 minutes
- Practical guidance for financial institutions subject to the enhanced AML whistleblower program - 20 minutes
Who Should Attend: In-house counsel, outside attorneys, compliance, finance, banking and other allied professionals interested in staying up-to-date on the enhanced BSA/AML whistleblower program
Program Level: Update
Advanced Preparation: None