On December 29, President Biden signed the Anti-Money Laundering (AML) Whistleblower Improvement Act into law. The Act is a landmark piece of anti-corruption that, in addition to strengthening AML whistleblower protections, expands the AML Whistleblower Program to cover whistleblowers disclosing violations of U.S. sanctions.
Since the AML Whistleblower Improvement Act became law, the U.S. Department of Justice (DOJ) has announced a number of charges against individuals who allegedly violated U.S. sanctions against Russia.
On January 20, the DOJ announced charges against two businessmen, Vladislav Osipov, a Russian national, and Richard Masters, a United Kingdom national, for allegedly facilitating a sanctions evasion and money laundering scheme concerning the Tango, a $90 million, 255-foot luxury yacht owned by sanctioned Russian oligarch Viktor Vekselberg.
According to the DOJ’s indictment, “despite U.S. sanctions issued against Vekselberg in April 2018, Osipov and Masters facilitated the operation of Tango through the use of U.S. companies and the U.S. financial system, attempting to obfuscate Vekselberg’s involvement in the vessel. Osipov, an employee of Vekselberg who functioned as a property manager for Tango, designed a complicated ownership structure of shell companies to hide Vekselberg’s ownership of the yacht, despite that Vekselberg designed the yacht, was the sole user, and was the ultimate beneficial owner.”
“Facilitators of sanctions evasion enable the...
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