What Companies Need to Know About FinCEN’s Proposed Whistleblower Program

A proposed rule implementing the whistleblower program from U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) could significantly increase enforcement risk for companies subject to anti-money laundering and sanctions laws—while creating powerful financial incentives for employees and third parties to report potential violations.... By: Orrick, Herrington & Sutcliffe LLP