U.S Treasury’s New Bank Secrecy Act Whistleblower Program
In perhaps the last major legislative action under this presidential administration, on New Year’s Day 2021, the U.S. Congress passed what could be the most significant anti-money laundering (AML) statute since the U.S. Patriot Act of 2001, as part of the annual National Defense Appropriations Act (NDAA). Among many changes to the existing AML regime, the new legislation creates a new whistleblower reward program, administered by the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN).
In a newly published article, the background that led to the enactment of this new legislation is analysed as well as the role that whistle-blowers have played in exposing misconduct in the past. Based on lessons learned, the article concludes by presenting measures that entities should take in response.