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Stephen Kohn presents Nuts and Bolts of Anti-Money Laundering Law in British Parliament

Stephen Kohn presents Nuts and Bolts of Anti-Money Laundering Law in British Parliament

The event was hosted by KKC and sponsored by Baroness Susan Kramer, who has championed whistleblower causes in the House of Lords.

KKC Partner, Stephen Kohn, spent last Thursday in the so-called “money laundering capital of the world” — London, England — to speak about the United States’ transnational anti-money laundering laws in the British House of Commons.

The event was hosted by KKC and sponsored by Baroness Susan Kramer, who has championed whistleblower causes in the House of Lords. It followed a two-day conference  hosted by WhistleblowersUK, which focused on the passage of the Protection of Whistleblowing bill. A broad constituency of stakeholders attended, including whistleblowers themselves, AML practitioners, professors, and politicians.

“If I could summarize my message in two words,” Kohn said, “they’d be: it works.”

Kohn was referring to the whistleblower model recently incorporated into the United States’ Anti-Money Laundering law, which Kohn and the National Whistleblower Center helped to draft.

The critical provisions of the U.S. law are (1) anonymity, (2) confidentiality, and (3) enforcement. Similar to proven best-practice whistleblower legislation like the Dodd-Frank Act, the U.S.’s Anti-Money Laundering Whistleblower Improvement Act protects whistleblowers by allowing them to report anonymously and incentivizes whistleblowers to report by offering a monetary reward equivalent to 10-30% of the sanction obtained.

The United States has identified the strategic importance of the AML Whistleblower law, stating in the whole-of-government Strategy on Countering Corruption that “The United States will implement newly established tools for investigating and prosecuting money laundering offenses [including]… financial rewards to incentivize reporting on the Bank Secrecy Act.”

Initially, some audience members expressed skepticism about the notion of rewards laws, citing that such laws could incentivize so-called bounty hunters to look for ways to report in order to make money.

“That is precisely the point,” Kohn responded. “The deterrent power of this law lies in the fear among corporations that more people will report. The end goal is not for whistleblowers to make a bunch of money… it’s for the existence of rewards to incentivize reporting such that corporations stop engaging in illegal money laundering.”

In the AML Whistleblower Improvement Act, as in other U.S. transnational whistleblower programs, non-U.S. citizens can qualify as whistleblowers and can report banks, companies, or individuals outside of the United States. Because the UK lacks substantive, effective whistleblower programs, and because fraud and money laundering is so rampant in the UK, many UK whistleblowers already utilize U.S. whistleblower laws. As of 2021, a cumulative 783 UK nationals had filed complaints under the Dodd-Frank whistleblower program.

After Kohn’s remarks, Georgina Halford-Hall, WBUK CEO, celebrated the launch of WhistleblowerUK’s newest report, which KKC helped to author, and which cites the success of U.S. whistleblower laws.

Money laundering whistleblowers in the United Kingdom can learn more about how to use the U.S. laws to anonymously report violations and gain financial rewards by navigating the FAQs made public by KKC or by setting up a free consultation.

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