Financial institutions lacking compliance and due diligence regarding money laundering are seeing increasing fines and their employees are coming forward with the information needed by the Treasury Department to establish the wrongdoing. In 2021 fines for non-compliance related to money laundering amounted to $2.7 billion. anti-money laundering professionals with specific information about non-compliance are taking advantage of a fairly new whistleblower program started in 2021 is called the anti-money laundering enforcement program. It is administered by the Department of Treasury and provides mandatory rewards to whistleblowers who bring forward information about violations of the Bank Secrecy Act. Under this whistleblower program, a whistleblower may receive a reward of up to 30% of the monetary sanctions over one million dollars the government imposes based on information provided by the whistleblower. Importantly, the program covers wrongdoing before the creation of this program. A whistleblower with information about any violation of the BSA that are within the statute of limitations -six years for civil actions under 31 U.S.C. Section 5321(b) and five years for criminal penalties can submit a claim under this program.
The elements of the violations may include the following:
*Failure of a covered financial institution to have an effective overall compliance program
*Violation or failures regarding specific compliance program components;
*Recurring non-compliance with Bank Secrecy Act requirements
*Complicity with financial institutions and money laundering entity
Whistleblowers do not have to be US citizens and may work in the compliance department of the institutions.
Some of the major AML fines have included
AMBank: $700 Million
ABN Amro $574 Million
Capitol One $390 Million
Deutsche Bank: $130 Million
Julius Baer: $79 Million
DNB ASA $48.1 Million
Apple Bank for Savings $12.5 Million
The single most significant reason for the fines is related to ignoring illegal activity.
For more information or for a confidential consultation, contact Jeffrey Newman of Jeff Newman Law, a firm handling major money laundering cases in this program. Attorney Newman can be reached at jeff@jeffnewmanlaw.com or at 617-823-3217.
