Nearly three years ago, Congress passed an Anti-Money Laundering Act that incentivized whistleblowers to report money laundering activities that violated the Bank Secrecy Act. However, because the resulting Whistleblower Program was fraught with uncertainty, few whistleblowers stepped forward. Well, in the final days of 2022, Congress addressed many of the concerns of the whistleblower community when it passed the Anti-Money Laundering Whistleblower Improvement Act.

Specifically, this law strengthened the AML Whistleblower Program by setting a minimum whistleblower award amount, establishing a funding mechanism for whistleblower awards, and explicitly expanding the program to reach violations of U.S. sanctions. In effect, Congress changed the AML Whistleblower program to more closely mirror the successful SEC Whistleblower program.

“Potential whistleblowers will not risk their livelihoods unless there are adequate protections,” explained Taxpayers Against Fraud president Jeb White. “This law provides a level of assurance that successful whistleblowers will be rewarded. Of note, every single penny of the whistleblower award ultimately comes from the wrongdoer.”

The near-term impact of the strengthened whistleblower program might be seen in the efforts to reach the funds of Russian oligarchs. Specifically, the AML Whistleblower Program now rewards disclosures of sanctions violations of the International Emergency Economic Powers Act, sections 5 and 12 of the Trading With the Enemy Act, and the Foreign Narcotics Kingpin Designation Act.