MoneyLaundering.com: Beneficial Owners and Sanctions Against Russia: Compliance in 2023
January 3, 2023
O’Melveny partner AnnaLou Tirol, former Deputy Director of the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN), shared her thoughts on what 2023 may bring with regard to FinCEN and the Anti-Money Laundering Act. “I would like to see whether the whistleblower program truly expands,” Tirol said. “FinCEN had a whistleblower program previously that only applied to a very specific number of violations, but the AML Act covers any alleged violation of the BSA. This not only means a broader program in terms of violations, but also in terms of the number of individuals who could qualify as whistleblowers, such as a member of an audit team inside a financial institution.”
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