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FinCEN and Kleptocracy Whistleblower Rewards Programs 

Under the whistleblower program administered by the Financial Crimes Enforcement Network (FinCEN), a bureau of the United States Department of the Treasury, individuals are eligible for a whistleblower award of up thirty 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. Violations of the anti-money laundering laws that could serve as basis for a whistleblower report and award may 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

In addition to the FinCEN Whistleblower Program, Congress established the Kleptocracy Asset Recovery Rewards Program in 2022. 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. 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 FinCEN or Kleptocracy Whistleblower Programs, please see the following resource offered by our firm:

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

For other whistleblower programs, visit:

Under the whistleblower program administered by the Financial Crimes Enforcement Network (FinCEN), a bureau of the United States Department of the Treasury, individuals are eligible for a whistleblower award of up thirty 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. Violations of the anti-money laundering laws that could serve as basis for a whistleblower report and award may 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

In addition to the FinCEN Whistleblower Program, Congress established the Kleptocracy Asset Recovery Rewards Program in 2022. 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. 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 FinCEN or Kleptocracy Whistleblower Programs, please see the following resource offered by our firm:

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

For other whistleblower programs, visit:

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