Key Takeaways

• On Dec. 23, 2022, Congress passed the Anti-Money Laundering Whistleblower Improvement Act, expanding whistleblower protections and strengthening incentives for reporting.
• The legislation establishes a minimum financial reward for whistleblowers, creates a fund supported by violation recoveries and allows citizens of any country in the world to confidentially report violations and participate in recovery.
• The Act aims, in part, to enforce U.S. sanctions against Russia to locate and seize hidden or laundered assets.

As one of its last acts of 2022, Congress aimed to close loopholes in the Anti-Money Laundering Act of 2020 (AMLA) that left it unclear how and how much whistleblowers would be paid. On Dec. 23, 2022, Congress passed the Anti-Money Laundering Whistleblower Improvement Act (AML Whistleblower Act) clarifying these open issues in an effort to encourage whistleblower cooperation.

The AMLA provided protection from retaliatory actions and confidentiality for whistleblowers as well as rewards of up to 30 percent of the amount exceeding $1 million recovered by the U.S. Treasury. The AML Whistleblower Act expands whistleblower protections and strengthens incentives for reporting. Whistleblowers who report sanctions violations or instances of money laundering will qualify for mandatory financial rewards. Similar to the Dodd-Frank whistleblower provisions applicable to Foreign Corrupt Practices Act violations, citizens of any country in the world can now...

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