Under the “internal controls” provision, issuers must devise and maintain a system of internal accounting controls sufficient to assure management’s control, authority, and responsibility over the firm’s assets. Internal controls over financial reporting are the processes used by companies to provide reasonable assurances regarding the reliability of financial reporting and the preparation of financial statements.
AML Whistleblower Act Rulemaking: Key Recommendations for FinCEN’s Final Regulations
In a 2023 letter to Attorney General, Secretary of the Treasury, and FinCEN Director, Kohn argued that the new AML whistleblower regulations must not only replicate the existing SEC and…
