Under the Improvement Act, whistleblowers can now receive awards for reporting violations of the Bank Secrecy Act and U.S. sanctions laws. In particular, the Act now covers violations of the International Emergency Economic Powers Act, Trading with the Enemy Act, and Foreign Narcotics Kingpin Designation Act. With this expanded scope, whistleblowers can now report the following types of violations:
- Anti-money laundering;
- Companies doing business with sanctioned individuals/entities or individuals/entities from a sanctioned country;
- Companies allowing sanctioned individuals/entities to use the company’s systems or tools;
- Companies failing to create and maintain effective compliance programs;
- Repeat noncompliance with rules and requirements.
