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August 8, 2022

In 2021, Congress passed the Anti-Money Laundering Act and, in doing so, created a whistleblower program focused on receiving information concerning violations of the anti-money laundering laws.  The Financial Crimes Enforcement Network, a bureau of the United States Department of the Treasury, is tasked with implementing and administering the Program. 

Under the AML Program, individuals are eligible for a whistleblower award of up to 30 percent of the monetary sanctions collected when information they provide to their employer, Treasury, or the Department of Justice leads to a judicial or administrative action under the Bank Secrecy Act resulting in more than $1 million in sanctions.  Though the Program has yet to issue an award, violations of the anti-money laundering laws that could serve as a basis for a whistleblower report and award may include:

  • Inadequate “know your customer” (KYC) verification processes
  • Failure to file suspicious activity reports (SARS)
  • Ineffective training and enforcement of anti-money laundering compliance programs

In addition to the FinCEN Whistleblower Program, in 2022 Congress established the Kleptocracy Asset Recovery Rewards Program.  The Program will provide rewards payments to whistleblowers who provide information leading to the seizure, restraint, or forfeiture of “stolen assets” linked to foreign government corruption. The Program will be operated by the Treasury’s Office of Terrorism and Financial Intelligence in conjunction with the Department of Justice, Department of State, and federal law enforcement agencies.

Treasury will receive all relevant whistleblower tips; however, it will also advertise certain issues about which the government is particularly interested in receiving information—currently including recent scandals relating to Odebrecht S.A., Braskem S.A., the government of the Russian Federation, and 1MDB.  The provision of information concerning these areas or other stolen assets linked to foreign government corruption could lead to a whistleblower award of up to $5 million, and potentially greater than $5 million where the Secretary of the Treasury determines the case warrants such an enhancement, awards the increase, and notifies Congress of her determination.

If you are considering filing a whistleblower complaint under the AML Whistleblower Program or the Kleptocracy Asset Recovery Rewards Program, please fill out our online form for a free, confidential consultation.


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