In Law360, Michael B. Himmel comments on proposed updates to anti-money laundering laws that will disclose beneficial ownership of shell corporations and create a national database that tracks entities or individuals with substantial control. "This is like a godsend to the bank compliance officers who are always scratching their heads and have no clue," Himmel says. "But not only is it going to be an assist to the banks, it's also going to be an assist to the Department of Justice in pursuing prosecutions."
Himmel describes the FinCEN Exchange‒the voluntary data-collection and sharing system among law enforcement agencies, national security agencies, financial institutions, and FinCEN to combat money laundering, terrorism financing, and organized crime‒as “a win-win situation. Most countries are going to want to cooperate with us because it's a two-way street.” Regarding the proposed award to tipsters of 30 percent of total monetary sanctions, he observes: "There certainly is much more of an incentive to whistle blow — not just to the individuals doing it, but to the lawyer who's going to be doing a quick investigation based upon what he's heard."