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August 5, 2021

Key Considerations for Financial Institutions Subject to the New AML Whistleblower Law (Video)


In January 2021, Congress passed sweeping AML reform, bringing the AML whistleblower provisions closer in line with the SEC’s successful whistleblower program. The new whistleblower law provides that individuals who voluntarily provide original information leading to the successful enforcement of violations of the AML laws will receive up to 30 percent of the monetary sanctions collected. The new whistleblower provisions also provide for enhanced confidentiality and retaliation protections of whistleblowers and authorizes the Treasury Secretary, in consultation with the Attorney General, to issue regulations implementing the provisions. 

Although the legislation is effective now, writing the associated rules is not yet on the Treasury Department’s regulatory agenda. Watch as Arnold & Porter’s partners Kevin Toomey, Kathleen Reilly, and Jane Norberg, former Chief of the Office of the Whistleblower at the SEC, discuss what this grey period prior to rule-making means and what some of the compliance and litigation considerations are for those who are subject to the legislation.