On April 18, 2023, Department of Commerce Assistant Secretary for Export Enforcement Matthew Axelrod issued a memorandum (Memorandum) that, while primarily focused on enforcement of export control restrictions, offered some noteworthy insights into the Bank Secrecy Act’s newly overhauled whistleblower program. That whistleblower program, originally enacted as part of the Anti-Money Laundering Act of 2020 (AMLA), was amended in early 2023 to authorize whistleblower awards for tips about not only Bank Secrecy Act (BSA) violations but also economic sanctions violations.
Expansive New Bank Secrecy Act, Sanctions Whistleblower Program: Department of Commerce Insights
