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March 23, 2022

Congress recently 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, including the Government of the Russian Federation. Information reported, the identity of the whistleblower, and any rewards paid will be kept strictly confidential to the greatest extent allowed by applicable law.

The Program is designed to further combat foreign government corruption by identifying and recovering stolen assets, forfeiting proceeds of corruption, and returning those stolen assets or proceeds to the country harmed by the acts of corruption where appropriate and feasible. The Program will be operated by the United States Department of the Treasury’s Office of Terrorism and Financial Intelligence in conjunction with the Department of Justice, Department of State, and federal law enforcement agencies.

What qualifies as “stolen assets” is specified by statute. Indeed, within this context, “stolen assets” are defined as financial assets within the jurisdiction of the United States constituting, derived from, or traceable to, any proceeds obtained directly or indirectly from foreign government corruption. And “financial assets” means funds, investments, or ownership interests, that, after January 1, 2021, are (1) in an account at a U.S. financial institution, including a U.S. branch of a foreign financial institution; (2) that come within the United States; or (3) that come within the possession or control of any U.S. person.

Treasury will receive all relevant whistleblower tips; however, it will also advertise certain areas about which the government is particularly interested in receiving information leading to the restraint, seizure, forfeiture, or repatriation of stolen assets linked to foreign government corruption. For example, federal agencies are currently seeking information leading to the seizure, restraint, forfeiture, or repatriation of bribes or assets linked to bribes paid by Odebrecht S.A., a global construction conglomerate based in Brazil, and Braskem S.A., a petrochemical company based in Brazil. In 2016, Odebrecht and Braskem pled guilty and agreed to pay approximately $3.5 billion in global penalties to resolve the largest foreign bribery case in history.

In addition, federal agencies are seeking information leading to the seizure, restraint, forfeiture, or repatriation of assets linked to corruption involving the government of the Russian Federation. And federal agencies are also seeking information leading to the seizure, restraint, forfeiture, or repatriation of assets linked to corruption involving the Sovereign Wealth Fund of Malaysia, known as 1MDB.

The provision of such information 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.

Reward eligibility will be considered on a case-by-case basis by the Interagency Review Committee. If the Review Committee finds an individual is eligible for a reward, it will recommend that the Secretary approve the reward of a suggested amount. Factors considered in determining reward amount include whether the information was previously known to investigating agencies, the risk assumed by the informant, and the significance of the information in leading to the restraint or seizure, forfeiture, or repatriation of the assets identified.

Reward eligibility will be restricted in two instances. First, foreign and U.S. federal, state, or local government employees furnishing information obtained in the performance of their official duties are ineligible for reward payments. Second, those involved in the underlying misconduct are subject to a mandatory reduction of any reward and may be subject to a denial of an award. And individuals convicted of criminal conduct relating to the underlying corruption shall be denied a reward and Treasury may seek to recover any reward already paid.

If you are considering reporting information to the IRS, please fill out our online form or contact us by phone at (267) 551-5240 or via e-mail at for a free, confidential consultation.


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