Last year, Congress amended the whistleblower rewards provision of the Anti-Money Laundering Act (AMLA) to require the Treasury to pay an award to a whistleblower for a voluntary disclosure of original information about sanctions evasion that results in the collection of sanctions above $1 million. In particular, the AMLA whistleblower reward law incentivizes whistleblowers to disclose violations of the International Emergency Economic Powers Act, sections 5 and 12 of the Trading With the Enemy Act, or the Foreign Narcotics Kingpin Designation Act.
A whistleblower can report violations of U.S. sanctions anonymously (if represented by an attorney) and can obtain an award of 10% to 30% of the collected monetary sanctions. The AMLA whistleblower reward program is modeled on the highly successful SEC whistleblower program. The monetary sanctions collected in any judicial or administrative action that qualify for an AMLA whistleblower award include penalties, disgorgement, and interest ordered to be paid, but excludes (i) forfeiture; (ii) restitution; and (iii) any victim compensation payment.
Recent developments in sanctions enforcement provide a strong incentive for whistleblowers to identify and report sanctions violations, including an increase in sanctions enforcement resources and the imposition of stiff penalties in sanctions enforcement matters.
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