Under the AML Whistleblower Program, whistleblowers who report potential money laundering violations are protected from retaliation. Protected disclosures include reporting any potential violation of federal law relating to records and reports on monetary instruments or criminal money laundering to the employer of the whistleblower, the appropriate U.S. authorities, any member of Congress, or the whistleblower’s supervisor or any person working at the employer who has the authority to investigate the misconduct.
Forms of retaliation prohibited by the AML whistleblower law include termination, demotion, reassignment to a less desirable position, harassment, blacklisting, as well as more subtle forms such as ostracization.
AML whistleblowers who have suffered retaliation have 90 days to file a complaint with the Occupational Safety and Health Administration (OSHA) Whistleblower Program. Whistleblowers who suffer retaliation are entitled to reinstatement, double back pay, and other relief.
Notably, however, the AML Whistleblower Program does not extend anti-retaliation protections to employees at banks that are covered under the Federal Deposit Insurance Act or 214 of the Federal Credit Union Act.