A domestic concern includes any individual who is a citizen, national, or resident of the United States, or any corporation, partnership, association, joint-stock company, business trust, unincorporated organization, or sole proprietorship, other than an issuer, that is organized under the laws of the United States or its states, territories, possessions, or commonwealths or that has its principal place of business in the United States. Officers, directors, employees, agents, or stockholders acting on behalf of a domestic concern, including foreign nationals or companies, are also covered by the FCPA.

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…



