Interstate commerce is defined in the FCPA as “trade, commerce, transportation, or communication among the several States, or between any foreign country and any State or between any State and any place or ship outside thereof ….” The term also includes the intrastate use of any interstate means of communication, or any other interstate instrumentality.
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…
