Takeaways:

• The Treasury Whistleblower Program now provides for guaranteed awards of 10% to 30% of the government recovery in covered actions
• The Treasury Whistleblower Program has been expanded to include not just tips concerning anti-money laundering violations but also those regarding various forms of sanctions evasion
• The new law goes hand-in-hand with the government’s aggressive crackdown on Russian sanctions evaders and those that assist them

During the holidays, in a rare bipartisan move, Congress passed the Anti-Money Laundering Whistleblower Improvement Act (“AMLWIA”), an unheralded law with massive implications for domestic and international whistleblowers.

I. The New Law Provides Whistleblowers a Real Incentive

Back in 2020, the government enacted the Anti-Money Laundering Act of 2020 (“AMLA”). AMLA provided certain retaliation protections for whistleblowers reporting violations of the anti-money laundering statutes (i.e., the Bank Secrecy Act). Just as critically, AMLA established that whistleblowers (both U.S. and foreign citizens) could receive monetary awards if they provide original information in reporting anti-money laundering violations to their employers or the government when such tips lead to successful actions by the Department of the Treasury (e.g., via FinCEN) or Department of Justice where the sanctions exceed $1 million.

This program (“the Treasury Whistleblower Program”) looked promising, but it failed to provide a real “carrot” for...

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