Davis Polk partner Dan Stipano was quoted in MoneyLaundering.com on the Financial Crimes Enforcement Network’s new whistleblower program, which makes awards for whistleblowers who provide novel information that leads to a considerable enforcement action mandatory and potentially larger. Dan notes that while the new higher cap on rewards all but promises to generate more anonymous tips for FinCEN to develop cases, it will take time to see whether the revamped program is on the same trajectory as the SEC’s. “I don’t know how big of a culture of whistleblowing the [Anti-Money Laundering] industry has,” Dan says. “Compliance professionals typically work through the management structure to try and fix things rather than blow the whistle.”

FinCEN’s New Whistleblower Program Open for Business,” MoneyLaundering.com (December 21, 2021) (subscription required)