On December 7, the U.S. Senate unanimously voted by voice to pass the bipartisan Anti-Money Laundering (AML) Whistleblower Improvement Act. The bill offers reforms to the AML Whistleblower Program which whistleblower advocates have called for since the program was established in January 2021. The bill also expands the program to cover whistleblowers disclosing sanctions violations.

“The whistleblower programs I’ve helped create have seen roaring success, with the False Claims Act saving taxpayers $70 billion, the SEC whistleblower program saving over $4.8 billion and the IRS whistleblower program saving over $6 billion,” said Senator Chuck Grassley(R-IA), one of the cosponsors of the bill. “I’m optimistic that our new program encouraging individuals to come forward for suspected sanctions violations will be successful as well. Given the expansive sanctions we’ve implemented on Russia as they wage an unjust war in Ukraine, our legislation is urgently needed to hold bad actors accountable.”

The two reforms found in the AML Whistleblower Improvement Act are modeled off provisions of the Dodd-Frank Act, which established the highly successful SEC and CFTC whistleblower programs. One provision specifies that under the AML Whistleblower Program, qualified whistleblowers will receive awards of “not less than 10 percent” of the sanctions collected in the relevant enforcement action. Currently there is no statutory minimum for AML whistleblower awards, meaning that awards are...

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