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Sunday, April 26, 2026

New AML whistleblower law is a game changer in enforcing ... - Reuters

January 18, 2023 - One of the last actions taken by the United States Congress in 2022 was enacting a new whistleblower law. The Anti-Money Laundering (AML) Whistleblower Improvement Act, which the author's firm actively supported, will have a direct impact on the ability of U.S. law enforcement agencies to track down assets held by Russian oligarchs and sanctioned entities.

Although the AML Whistleblower Improvement Act broadly covers violations of both money laundering and sanctions requirements, the ability to use this law immediately to enforce all of the financial restrictions placed on Russia after the invasion of Ukraine was the driving force behind its passage.

At the 11th hour, the whistleblower law was attached to the Omnibus Budget bill signed into law by President Biden on Dec. 29, 2022. It was one of the very few non-budget items included into the massive end-of-the-year federal spending bill.

Senator Charles Grassley, the principal sponsor of the bill, explained in a Dec. 8, 2022, press release that a primary target of the new law was Russia: "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."

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Senator Grassley further explained why Congress was acting during a "lame duck" session to quickly pass this whistleblower law: "The bipartisan, bicameral proposal expands on an anti-money laundering whistleblower program by adding support...



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