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Anti-Money Laundering and Sanctions Whistleblower Program

Whistleblowers can help enforce money laundering and U.S. sanctions violations.

Anti-Money Laundering Act and Anti-Money Laundering Whistleblower Improvement Act

The anti-money laundering whistleblower program incentivizes individuals to report money-laundering and U.S. sanctions violations. Under the program, which is administered by the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), qualifying whistleblowers can receive a monetary award if the information they provide leads to recoveries exceeding $1 million.

In 2021, Congress enacted the Anti-Money Laundering Act of 2020 (“AMLA”), bringing about the most comprehensive set of changes to the Bank Secrecy Act since its inception. Among the new provisions was a significantly enhanced whistleblower reward program, which is administered by the Department of Treasury. The whistleblower program was further expanded in 2022 when Congress passed the Anti-Money Laundering Whistleblower Improvement Act.

Covered Conduct

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.

The Anti-Money Laundering Whistleblower Program Rewards and Protects Whistleblowers

The Anti-Money Laundering Whistleblower Improvement Act expanded the scope of potential whistleblowers and enacted enhanced whistleblower awards. Key components of the program include the following:

  • Whistleblowers do not have to be industry insiders. However, corporate auditors and compliance professionals can also qualify as whistleblowers.
  • Whistleblowers who provide voluntary, original information relating to a violation can receive between 10% and 30% of resulting monetary sanctions over $1,000,000.
  • The amount of the award depends on the value of the information and the degree of assistance that the whistleblower provides.
  • Employers cannot retaliate against whistleblowers who report AML violations.
  • Whistleblowers who are represented by an attorney can report information anonymously, though they must reveal their identity to the Treasury Department before they receive an award.
  • The program is international: whistleblowers can be from outside of the United States and report violations that took place outside of the United States.

Contact Us

If you think you may have information relating to money laundering or U.S. sanctions violations, fill out our contact form or call us at (212) 376-5666 for a free evaluation of your potential case.

We represent our whistleblower clients on a contingent fee basis, meaning that an attorney’s fee is paid only if your case is successful.