The National Defense Authorization Act was enacted on January 1, 2021, after the Senate joined the House in overriding President Trump’s veto of the bill. In addition to authorizing appropriations for the Department of Defense, the new law also contains several provisions designed to improve policies and procedures aimed at policing money laundering and terrorism financing.
One of the new provisions updates the AML whistleblower program already in place to encourage whistleblowers to report violations of the AML laws, and establishes a fund to pay whistleblower rewards.
In a new legal update, “New whistleblower provisions for reporting AML violations,” Kevin Harnisch, Partner in the Norton Rose Fulbright Washington DC office, Glen Barrentine, Of Counsel in the Norton Rose Fulbright Denver office, and Ilana Sinkin, Senior Associate in the Norton Rose Fulbright Washington DC office, discuss the details of the new law, including who is eligible for the awards, the anti-retaliation protection and what is taken into consideration in determining the amount of the award.
We also have a blog post on another AML provision in the new law on the new requirement that nonpublic companies report their beneficial owners to the Financial Crimes Enforcement Network (FinCEN), the US AML agency.