Anti-Money Laundering Whistleblower Program covers wrongdoing by banks before the passage of the law in some cases six years back

The anti-money laundering whistleblower program which is administered by the Treasury Department and provides for mandatory rewards of up to 30% of the monetary sanctions over one million dollars imposed, can take the form of *failure of a financial institution to have an effective overall compliance program or systematic and recurring noncompliance with Bank Secrecy Act requirements. The program covers wrongdoing before its creation. So a whistleblower with information about any violations of the Bank Secrecy Act that are within the statute of limitations for government enforcement actions-six years for civil actions under the False Claims Act and five years for criminal penalties under 18 USC Sec 3282(a)-can submit a claim under the AML whistleblower program.

JEFFREY NEWMAN IS A WHISTLEBLOWER LAWYER WITH THE FIRM NEWMAN & SHAPIRO AND CAN BE REACHED AT JNEWMAN@NEWMANSHAPIRO.COM OR AT 617-823-3217