The AML Whistleblower Program
In 2022, Kohn, Kohn & Colapinto won a major victory with the passage of the AML Whistleblower Improvement Act. After publicly identifying loopholes in the whistleblower provisions of the AML Act, KKC worked pro bono alongside National Whistleblower Center and Whistleblower Network News to lead a successful grassroots campaign advocating for the bill’s passage.
The AML Whistleblower Improvement Act offered necessary reforms to establish an effective whistleblower award program for individuals reporting money laundering as well as sanctions violations.
The Rulemaking Process
The Treasury Department and Financial Crimes Enforcement (FinCEN) are now drafting regulations implementing the AML Whistleblower Program. Kohn, Kohn & Colapinto is continuing to work pro bono to ensure that the regulations work well for whistleblowers, particularly international whistleblowers.
On June 26, Kohn, Kohn & Colapinto sent a letter to the Treasury and FinCEN outlining the need to adopt regulations which consider the needs of international whistleblowers. The letter emphasizes that the AML Whistleblower Program is primed to play a key role in global anti-corruption efforts but that the rules must account for the unique challenges facing international whistleblowers and the avenues through which they blow the whistle.
“Given the central role money laundering plays in enabling corruption to flourish, and the well-documented role that whistleblowers play in detecting corruption, FinCEN must use this opportunity to craft regulations that will ensure that whistleblowers are fully incentivized to report in a manner consistent with the needs and customs of international whistleblowers,” the letter states.
In the letter, the attorneys of Kohn, Kohn & Colapinto give detailed recommendations for regulations which would best support international whistleblowers and best position the AML Whistleblower Program to fight corruption across the globe.
KKC founding partner Stephen M. Kohn outlined the recommendations for the AML whistleblower program in an article for the Columbia Law School Blue Sky Blog entitled “Treasury Should Keep Global Anti-Corruption Efforts in Mind When Drafting Whistleblower Regs.”
Related Articles
Press & Media
Official House Report on The AML Whistleblower Law
H. Rept. 117-423
TO PROVIDE FOR CERTAIN WHISTLEBLOWER INCENTIVES AND PROTECTIONS
The Hill
Congress needs to pass money laundering and sanctions-busting whistleblower protections | The Hill
KKC Focused on the Issues
Advocating for Necessary Fixes to the Anti-Money Laundering Whistleblower Law
The National Law Review
https://www.natlawreview.com/article/aml-bill-key-to-busting-russian-oligarchs
JD Supra
https://www.jdsupra.com/legalnews/danske-bank-scandal-proves-need-for-aml-9514513/
Connecticut Post (ctpost)
Opinion: DeLauro action needed to pass whistleblower protection act
