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This clip was part of the annual Virtual Conference. Found here - [ Ссылка ]
Now let's flip to page four and talk about those whistleblower rules. I talked about this a little bit earlier, but again, they're increasing the incentives for internal employees to turn their companies in. Okay? So, this is something your board of directors and management team should be aware of because there was a whistleblower rule out there before, but this new rule structure is far... It's incentivizing more activity. Honestly, I think it's going to create a cottage industry for law firms to go out and actively try to get employees to blow the whistle on their employers because there are some major incentives here and there are some major protections if an employee decides to be a whistleblower. Let's make sure we understand the concepts here and we're all on the same page. First, what is a whistleblower? You can look at the page, there it is.
Any individual who is providing information related to a BSA violation to their employer, if they're talking to their employer on one hand or to the federal government, okay? That's how you become a whistleblower. It includes compliance and BSA staff. So your BSA team can be whistleblowers. If management is doing something that could be a violation and they're not doing enough about it, you could have a potential whistleblower on your team. It does not include the information that was derived from an audit. Okay? Now, why is that? The rule still wants to allow auditors to come in and be honest and open about what's going on and they don't want management to be afraid of what their auditors may or may not know. So, if they're getting information through an audit process, then that's a carve-out. Okay? What they're looking at are people who are in the programs who are blowing the whistle on their management teams.
