On December 23, 2022, Congress included the Anti-Money Laundering Whistleblower Improvement Act as part of the Omnibus Budget President Biden has now signed into law. The Act includes drastic new measures to expand enforcement against kleptocratic money launderers operating in the United States financial system and abroad, chiefly by expanding the incentives for whistleblowers with knowledge of illicit conduct. The most important update to these whistleblower laws is that corporate auditors and compliance professionals can now qualify as whistleblowers. This is a significant expansion to include more eligible financial professionals typically prohibited from claiming an award under the Securities and Exchange Commission’s Office of the Whistleblower created under the Dodd-Frank Act in 2010.
Though large payouts under the U.S.’ various whistleblower programs routinely make the news and significant awards are increasing in frequency, would-be whistleblowers are often discouraged to learn that little-known statutory exclusions render them ineligible for an award. The logical result of these exclusions is that fewer whistleblowers with information of illicit financial conduct come forward, the government’s enforcement priorities are stymied, and our financial systems suffer continued abuse.
The Anti-Money Laundering Whistleblower Improvement Act eliminated many award eligibility barriers and increased the scope of reportable conduct which can entitle one to an award. The Act...
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