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Whistleblowers U.S. Treasury

Hudson Cook, LLP

CFPB Bites of the Month - August 2024 - All That's Left of the CFPB's Summer Sky

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In this month's article, we share some of our top "bites" for the prior and current month covered during the August 2024 webinar....more

Dechert LLP

What Dealmakers Should Know about Congress’ Wish List for CFIUS

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Congress continues to put pressure on the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”), increasingly informing the context in which the Committee conducts its work. Last week, for...more

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - October 2023

The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more

Jones Day

Federal Agencies Highlight Benefits of Self-Disclosure, Emphasize Enforcement of Trade Violations in Tri-Seal Compliance Note

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In a coordinated announcement, federal agencies stress the benefits of voluntarily disclosing potential trade violations while emphasizing increased enforcement....more

Husch Blackwell LLP

The Government Continues to Prioritize Export Control and Sanctions Enforcement Highlighted in New Tri-Seal Compliance Note and...

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On Wednesday, July 26, the Departments of Commerce, Treasury, and Justice issued a Tri Seal Compliance Note detailing the voluntary self-disclosure of potential violations for export controls, sanctions, and other national...more

K2 Integrity

DOJ, BIS, and OFAC Issue Tri-Seal Compliance Note Consolidating Information Regarding Voluntary Self-Disclosure Policies

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The U.S. Department of Justice (DOJ), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published their second Tri-Seal...more

Paul Hastings LLP

DOJ OFAC BIS Joint Compliance Note and Enhanced Coordination Highlights Increased Enforcement Risk

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On July 26, 2023, the U.S. Departments of Justice, Treasury, and Commerce issued a joint compliance note (“JCN”) regarding voluntary self-disclosure (“VSD”) policies that apply to potential violations of U.S. sanctions...more

Ballard Spahr LLP

“Tri-Seal” Compliance Notice: U.S. Authorities Release Joint Guidance on Voluntary Self-Disclosure of Potential Sanctions and...

Ballard Spahr LLP on

On July 26, the Department of Commerce, the Department of the Treasury, and the Department of Justice released a joint compliance notice (the “Compliance Notice”) updating and summarizing each agency’s position regarding the...more

Skadden, Arps, Slate, Meagher & Flom LLP

US Authorities Hammer Home the Importance of Self-Disclosing Sanctions and Export Control Violations

On July 26, 2023, the U.S. Department of Justice’s (DOJ’s) National Security Division (NSD), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury’s Office of Foreign...more

Kohn, Kohn & Colapinto LLP

Treasury and FinCEN are Taking the New AML Law Seriously

When President Biden signed the Anti-Money Laundering (AML) Whistleblower Improvement Act on December 29th, 2022, the Treasury Department had its work cut out for them. In the shadow of the highly successful Securities and...more

Torres Trade Law, PLLC

New Anti-Money Laundering Whistleblower Law Makes Economic Sanctions Violations Reportable

To more effectively counter transnational corruption and economic sanctions evasion, recent changes to the U.S. anti-money laundering (“AML”) whistleblower regime expand and reinforce whistleblower protections and rewards in...more

Pietragallo Gordon Alfano Bosick & Raspanti,...

Congress Fixes Major Hole In Treasury’s Nascent Whistleblower Program While Expanding Its Scope To Sanctions Evaders

Takeaways: •The Treasury Whistleblower Program now provides for guaranteed awards of 10% to 30% of the government recovery in covered actions- •The Treasury Whistleblower Program has been expanded to include not just tips...more

Kohn, Kohn & Colapinto LLP

The Anti-Money Laundering Whistleblower Improvement Act: Justice for Whistleblowers; No Peace for Russian Oligarchs

A two-year campaign to create an effective law incentivizing whistleblowers to report money laundering and sanctions busting has ended with a stunning and surprise victory for whistleblowers. It started in December 2020 when...more

Freeman Law

Treasury Issues Proposed Regulations on IRS Appeals Procedures

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Taxpayers routinely resolve their tax controversy matters without resort to litigation.  Indeed, good tax professionals will often seek to avoid costly and time-consuming litigation, if possible, by utilizing various...more

Kohn, Kohn & Colapinto LLP

Treasury Department Rules Could Help Strengthen AML Whistleblower Program

The U.S. Treasury Department is currently drafting proposed rules to implement the whistleblower provisions of the Anti-Money Laundering (AML) Act of 2020. These rules will help determine the future success of the newly...more

Perkins Coie

AMLA 2020 Series Part 2: New Bank Secrecy Act Whistleblower Provisions

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On New Year’s Day 2021, Congress passed the Anti-Money Laundering Act of 2020 (AMLA 2020). As we reported last April, the AMLA 2020 included sweeping reforms aimed at strengthening protections against money laundering,...more

Fox Rothschild LLP

COVID-19 Fraud Task Force Established

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Intensifying its crackdown on suspected fraud in pandemic relief programs, the U.S. Department of Justice has established the COVID-19 Fraud Enforcement Task Force, sending a clear message that any individual or business that...more

Foley & Lardner LLP

Review of Recent Whistleblower Developments

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Whistleblower Developments is a periodic report covering significant cases, decisions, proposals, and legislation related to whistleblower statutes and how they may impact your business. Recent developments include: SEC...more

Buchalter

Treasury’s New Bank Secrecy Act Whistleblower Program

Buchalter on

In perhaps the last major legislative action under this presidential administration, on New Year’s Day 2021, Congress passed—over President Trump’s veto—what could be the most significant anti-money laundering (AML) statute...more

Jones Day

New Treasury Department Whistleblower Reward Program Targets Foreign Corruption

Jones Day on

The Kleptocracy Asset Recovery Rewards Act ("KARRA") authorizes a U.S. Treasury Department ("Treasury") pilot program aimed at rewarding whistleblowers who provide information leading to the restraint, seizure, forfeiture, or...more

Pillsbury Winthrop Shaw Pittman LLP

Legislative Reform Will Reinvent the US Anti-Money Laundering Regulatory Landscape

New federal requirements in the annual national defense budget reauthorization effectively will end anonymous U.S. shell companies by requiring businesses to disclose 25 percent owners and control persons to a newly created...more

King & Spalding

New BSA/AML Regime Promises Sweeping Changes

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As we wrote over the summer, Congress has passed a bill that will require certain corporations and limited liability companies (“LLCs”) to report information on their beneficial owners to the U.S. Treasury Department’s...more

Vinson & Elkins LLP

Congress Expands The Scope Of Anti-Money Laundering Rules—Disclosing Beneficial Owners Now Required

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The National Defense Authorization Act for FY 2021 (“NDAA”) passed Congress on December 11, 2020, with a “veto-proof” margin. Included within the NDAA are a number of anti-money laundering provisions with import for companies...more

ArentFox Schiff

Municipal VRDO Class Action Survives Banks’ Request for Dismissal

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Financial institutions should work with outside counsel to ensure that their internal policies and external actions minimize conduct that may violate state and Federal laws and regulations, and incentivize employees to reward...more

Eversheds Sutherland (US) LLP

New guidance issued on Paycheck Protection Program; loans with original amounts under $2 million will be deemed in good faith

The Treasury and the Small Business Administration (SBA) today updated its set of Frequently Asked Questions (FAQs) with respect to the Paycheck Protection Program (PPP) established under the Coronavirus Aid, Relief, and...more

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