Federal Reserve Bank Ruled a Federal Supervisory Agency Under the BSA

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In a case of first impression, a district court held that a regional Federal Reserve Bank was a supervisory agent as defined by the Bank Secrecy Act (“BSA”). The BSA requires the reporting of any suspicious activity that may constitute a violation of tax, anti-money laundering, and other laws and contains expansive whistleblower protections. The law prohibits discrimination or retaliation against employees that provide information to the “Secretary of the Treasury, the Attorney General, or any Federal Supervisory agency regarding a possible violation” of the BSA.

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