A new whistleblower reward program included in the Anti-Money Laundering Act of 2020 may lead to a surge in Bank Secrecy Act enforcement actions, Buchalter attorneys explain. They offer guidance for financial institutions to prepare, including updating compliance programs, encouraging internal reporting, and when to make self-disclosures.

The Anti-Money Laundering Act of 2020 (AMLA), which took effect Jan. 1, creates a new whistleblower reward program in the Treasury Department to encourage insider reporting of financial institutions’ violations of the Bank Secrecy Act (BSA).

As with similar programs created in the Securities and Exchange Commission and other federal agencies, this new reward program may lead to a surge of new BSA investigations and enforcement actions by Treasury. Financial institutions subject to the BSA—such as banks, credit unions, money service firms, casinos, and some fintech providers—should embrace the lessons learned from earlier whistleblower actions and prepare for this new form of enforcement risk.

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