The Treasury Department has a rare opportunity on its hands. Significant changes to its anti-money-laundering whistleblower program have the potential to cripple money-laundering networks by altering the landscape for financial services professionals. The question is — will it work in practice?

The answer depends on how the Treasury implements these new laws and if the program will provide sufficient incentives to ensure that whistleblowing is both confidential and financially rewarding.

The AML whistleblower program was created in 2020, though the Treasury has not yet issued regulations to specify exactly how the program will work. With amendments added in January, the program's significant potential to aid law enforcement is far more viable. These new amendments require the government to pay whistleblowers a minimum award and establish a dedicated fund for the payments of those awards. Today, an eligible whistleblower who provides the Treasury or Department of Justice with information that leads to an AML enforcement action and monetary recovery of over $1 million is entitled to an award of at least 10% and up to 30% of the recovered amounts.

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