The Anti-Money Laundering (AML) Whistleblower Program is primed for a big 2024 according to leading whistleblower attorney Stephen M. Kohn of Kohn, Kohn & Colapinto. In a new article for Bloomberg, Kohn outlines how the program is set up to be a game changer for the United States’ anti-corruption efforts.
“The Anti-Money Laundering Whistleblower Improvement Act has potential to be the most effective transnational anti-corruption law on the books,” writes Kohn. “In 2024, the law, and the AML Whistleblower Program it established, should start to deliver on this potential as whistleblower award programs continue to play a more central role in US global anti-corruption efforts.”
Kohn explains that while the AML Whistleblower Program dates back to 2020, the AML Whistleblower Improvement Act, which passed in the final days of 2022, made necessary reforms to turn the program into an effective whistleblower award program. The program should revolutionize the United States’ ability to crack down on money laundering and sanctions busting, two crimes at the heart of corruption worldwide.
Kohn further notes that other U.S. whistleblower award programs, like the SEC Whistleblower Program, have already proven to be extremely effective at incentivizing whistleblowers from around the world to report corruption to U.S. authorities.
“The table is clearly set for the AML Whistleblower Program to take a leading role in the US’ global efforts in 2024, but two major questions remain in determining the program’s success: Will the Treasury Department and FinCEN fully use the program, and will the regulations for the program align with unique needs of international anti-corruption whistleblowers?” writes Kohn.
According to Kohn, the rulemaking process for the AML Whistleblower Program will be critical in determining its efficacy. He has written extensively about how the rules need to work for international whistleblowers.