One Year Later: Addressing Whistleblower Risks Under the AMLA
A discussion of the Anti-Money Laundering Act (AMLA), including background, key distinctions between it and the SEC's whistleblower program, and tips on how to prepare for whistleblower risks arising under the Act.
January 31, 2022 at 10:00 AM
8 minute read
Whistleblower Laws
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.
AMLA now provides significant incentives to, and protections for whistleblowers who voluntarily provide original information to their employer, Treasury, or the U.S. Department of Justice (DOJ). AMLA's strong incentives and protections for employees may encourage more employees and plaintiffs' attorneys to take the risk of exposing potential money laundering or technical BSA violations by providing tips to law enforcement.
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
NOT FOR REPRINT
© 2024 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
You Might Like
View All
Recent Developments Under New York's Amended Whistleblower Protection Law
9 minute read
Former McKinsey & Co. Partner Sues Firm for Defamation Over 'Scapegoating'
Internal Investigations and Self-Disclosures in a Time of Enhanced Whistleblower Incentives
8 minute read
Law Firms Mentioned
Trending Stories
- 1Judicial Ethics Opinion 24-61
- 2Decision of the Day: School District's Probe Was a 'Sham'; Title IX Administrator Showed Sex-Based Bias
- 3US Magistrate Judge Embry Kidd Confirmed to 11th Circuit
- 4Shaq Signs $11 Million Settlement to Resolve Astrals Investor Claims
- 5McCormick Consolidates Two Tesla Chancery Cases
Who Got The Work
Michael G. Bongiorno, Andrew Scott Dulberg and Elizabeth E. Driscoll from Wilmer Cutler Pickering Hale and Dorr have stepped in to represent Symbotic Inc., an A.I.-enabled technology platform that focuses on increasing supply chain efficiency, and other defendants in a pending shareholder derivative lawsuit. The case, filed Oct. 2 in Massachusetts District Court by the Brown Law Firm on behalf of Stephen Austen, accuses certain officers and directors of misleading investors in regard to Symbotic's potential for margin growth by failing to disclose that the company was not equipped to timely deploy its systems or manage expenses through project delays. The case, assigned to U.S. District Judge Nathaniel M. Gorton, is 1:24-cv-12522, Austen v. Cohen et al.
Who Got The Work
Edmund Polubinski and Marie Killmond of Davis Polk & Wardwell have entered appearances for data platform software development company MongoDB and other defendants in a pending shareholder derivative lawsuit. The action, filed Oct. 7 in New York Southern District Court by the Brown Law Firm, accuses the company's directors and/or officers of falsely expressing confidence in the company’s restructuring of its sales incentive plan and downplaying the severity of decreases in its upfront commitments. The case is 1:24-cv-07594, Roy v. Ittycheria et al.
Who Got The Work
Amy O. Bruchs and Kurt F. Ellison of Michael Best & Friedrich have entered appearances for Epic Systems Corp. in a pending employment discrimination lawsuit. The suit was filed Sept. 7 in Wisconsin Western District Court by Levine Eisberner LLC and Siri & Glimstad on behalf of a project manager who claims that he was wrongfully terminated after applying for a religious exemption to the defendant's COVID-19 vaccine mandate. The case, assigned to U.S. Magistrate Judge Anita Marie Boor, is 3:24-cv-00630, Secker, Nathan v. Epic Systems Corporation.
Who Got The Work
David X. Sullivan, Thomas J. Finn and Gregory A. Hall from McCarter & English have entered appearances for Sunrun Installation Services in a pending civil rights lawsuit. The complaint was filed Sept. 4 in Connecticut District Court by attorney Robert M. Berke on behalf of former employee George Edward Steins, who was arrested and charged with employing an unregistered home improvement salesperson. The complaint alleges that had Sunrun informed the Connecticut Department of Consumer Protection that the plaintiff's employment had ended in 2017 and that he no longer held Sunrun's home improvement contractor license, he would not have been hit with charges, which were dismissed in May 2024. The case, assigned to U.S. District Judge Jeffrey A. Meyer, is 3:24-cv-01423, Steins v. Sunrun, Inc. et al.
Who Got The Work
Greenberg Traurig shareholder Joshua L. Raskin has entered an appearance for boohoo.com UK Ltd. in a pending patent infringement lawsuit. The suit, filed Sept. 3 in Texas Eastern District Court by Rozier Hardt McDonough on behalf of Alto Dynamics, asserts five patents related to an online shopping platform. The case, assigned to U.S. District Judge Rodney Gilstrap, is 2:24-cv-00719, Alto Dynamics, LLC v. boohoo.com UK Limited.
Featured Firms
Law Offices of Gary Martin Hays & Associates, P.C.
(470) 294-1674
Law Offices of Mark E. Salomone
(857) 444-6468
Smith & Hassler
(713) 739-1250
