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Anti-Money Laundering (AML) and Kleptocracy Whistleblower Rewards Programs 

The Anti-Money Laundering Act of 2020, as amended by the Consolidated Appropriations Act, 2023, established a whistleblower program that provides financial rewards and protections against retaliation for individuals reporting violations of the Bank Secrecy Act (BSA), an anti-money laundering law, and certain sanctions laws.  Whistleblowers may report BSA violations to the Financial Crimes Enforcement Network (FinCEN), a bureau of the United States Department of the Treasury, and sanctions violations to the Office of Foreign Assets Control (OFAC), a Treasury agency.  AML whistleblowers are eligible to receive between 10 to 30 percent of monetary sanctions recovered by Treasury in a covered judicial or administrative action exceeding $1 million.

BSA violations that could serve as basis for an AML whistleblower report and award include:

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

Violations of the following sanctions laws may serve as basis for an AML whistleblower report and award:

  • The International Emergency Economic Powers Act
  • The Foreign Narcotics Kingpin Designation Act
  • The Trading with the Enemy Act

In addition to the AML Whistleblower Program, Congress established the Kleptocracy Asset Recovery Rewards Program in 2022. The Program provides rewards payments to whistleblowers who provide information leading to the seizure, restraint, or forfeiture of “stolen assets” linked to foreign government corruption. Treasury will receive all relevant whistleblower tips; however, it will also advertise certain issues about which the government is particularly interested in receiving information, 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.

To learn more about filing a tip under the AML or Kleptocracy Whistleblower Programs, please see the following resources offered by our firm:

If you are considering reporting information concerning misconduct involving money laundering, sanctions, or corruption, please fill out our online form for a free confidential consultation.

For other whistleblower programs, visit:

The Anti-Money Laundering Act of 2020, as amended by the Consolidated Appropriations Act, 2023, established a whistleblower program that provides financial rewards and protections against retaliation for individuals reporting violations of the Bank Secrecy Act (BSA), an anti-money laundering law, and certain sanctions laws.  Whistleblowers may report BSA violations to the Financial Crimes Enforcement Network (FinCEN), a bureau of the United States Department of the Treasury, and sanctions violations to the Office of Foreign Assets Control (OFAC), a Treasury agency.  AML whistleblowers are eligible to receive between 10 to 30 percent of monetary sanctions recovered by Treasury in a covered judicial or administrative action exceeding $1 million.

BSA violations that could serve as basis for an AML whistleblower report and award include:

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

Violations of the following sanctions laws may serve as basis for an AML whistleblower report and award:

  • The International Emergency Economic Powers Act
  • The Foreign Narcotics Kingpin Designation Act
  • The Trading with the Enemy Act

In addition to the AML Whistleblower Program, Congress established the Kleptocracy Asset Recovery Rewards Program in 2022. The Program provides rewards payments to whistleblowers who provide information leading to the seizure, restraint, or forfeiture of “stolen assets” linked to foreign government corruption. Treasury will receive all relevant whistleblower tips; however, it will also advertise certain issues about which the government is particularly interested in receiving information, 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.

To learn more about filing a tip under the AML or Kleptocracy Whistleblower Programs, please see the following resources offered by our firm:

If you are considering reporting information concerning misconduct involving money laundering, sanctions, or corruption, please fill out our online form for a free confidential consultation.

For other whistleblower programs, visit:

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