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Money Laundering and the U.S. Anti-Money Laundering Whistleblower Program

Money Laundering and the U.S. Anti-Money Laundering Whistleblower Program

The U.S.’s new anti-money laundering whistleblower rewards program was enacted in 2021. This program is designed to reward whistleblowers for reporting insider information about some person or entity violating the U.S. anti-money laundering laws. The idea of this program is that it should allow whistleblowers to report wrongdoing and not be punished for doing so. The hope is that because of these protections and potential financial incentives, more people will come forward and report money laundering crimes, which will lead to a higher rate of prosecutions and convictions related to crimes involving money laundering and other types of financial frauds.

The way this program works is relatively simple. If you have any inside information about someone or some entity breaking U.S. anti-money laundering laws, specifically sanctions violations or violations of the Bank Secrecy Act, you can report this information to the U.S. government (it essential to follow all legal procedural requirements of FinCEN's whistleblower program.) If your information is found to be true and of the kind the government wants to pursue and leads to a successful enforcement action where the government collects money, then you may be rewarded a percentage of the money that was recovered from the violators.

This program provides an incentive for people to come forward and report any wrongdoing they may know about related to money laundering. The hope is that this will help crackdown on financial fraud occurring not just in the U.S. but around the world. Money laundering is a harmful crime because it helps finance terrorist activities and other illicit activities. The anti-money laundering whistleblower rewards program is just one way that the U.S. government is trying to combat this problem.

Money Laundering and How the Anti-Money Laundering Whistleblower Program Works

Money laundering is carried out by individuals trying to mask the origins of large sums of money. It is generally done to conceal money generated from criminal activities. To aid the government in prosecuting and holding those who launder money accountable, a whistleblower program was first created in 1984 so that people who had information on money laundering activities could report them. After its inception, the program was barely used due to several limitations which limited its appeal. Among them was a cap that limited awards granted to whistleblowers for their information. Additionally, no provisions were included providing protections to whistleblowers if they suffered retaliation for blowing the whistle on these types of activities from their employers. Given these drawbacks, most people were not willing to come forward, especially given the negative consequences they could be exposed to and the limited financial incentive involved.

On January 1st of 2021, Congress passed the National Defense Authorization Act for Fiscal Year 2021 (NDAA). Among the many provisions contained in this law, it included the most substantial and sweeping legislative reforms to Unite States anti-money laundering (AML) and counter-terrorism financing laws since the United States Patriot Act of 2001. Specifically, this law sought to greatly improve the whistleblower program that existed for money laundering activities which, until that moment was ineffective.

To improve the AML whistleblower program, the NDAA eliminated the cap of $150,000 that existed for awards given to whistleblowers. Under the new legislation, whistleblowers that report suspected AML violations can receive up to 30 percent of all monetary sanctions recovered in enforcement actions resulting from their tips. No minimum percentage was established, as exists for other whistleblower programs. Employers are now also prohibited from retaliating or discriminating against employees who report suspected AML violations. This new provision allows affected whistleblowers to sue their employers for compensatory damages, reinstatement, and other relief including double back-pay with interest, litigation costs, and attorneys’ fees. This greatly enhances the appeal of the program since, without these protections against retaliation, many individuals would hesitate to come forward and blow the whistle on their employers. Between these two changes, the appeal of the program has greatly increased. From a practical point of view, many of the individuals who possess the necessary information to bring one of these cases forward work in the financial sector. Given the salaries these employees earn, without adequate financial compensation and protection from retaliation, before the reform they were not many of them willing to blow the whistle.

To be eligible to receive an award under this program, the following criteria must be met:

  • An individual must voluntarily report their information and submit their evidence, following all applicable legal procedures, to FinCEN, via FinCEN's whistleblower program.
  • The information must be original;
  • The information must lead to a successful enforcement action; and
  • The resulting enforcement action must lead to the government recovering at least $1 million.

Unlike other whistleblower programs, such as the one at the Securities and Exchange Commission, this program does not exclude compliance personnel, internal or external auditors, or legal counsel from being eligible to receive an award.

The Financial Crimes Enforcement Network (FinCEN), a bureau within the United States Department of the Treasury, is the government office tasked with managing this whistleblower program. When submitting their information to FinCEN, whistleblowers can do so and identify themselves in the process or they can do so anonymously. To submit information anonymously, the whistleblower must be represented by legal counsel. If the information leads to a successful enforcement action and the whistleblower becomes eligible to receive an award, they must then disclose their identity to the Secretary of the Treasury if they wish to receive it.

Money laundering is not only a crime in of itself, but it is usually a crime committed after other crimes have been committed and illicit profits have been made. In its fight against these activities, the government usually lacks the required evidence to effectively enforce its laws. The difficulty involved in enforcing anti-money laundering laws is exponentially increased when dealing with sophisticated criminals in an age when many transactions occur digitally. Emboldened by the protections provided by the NDAA, whistleblowers are aid the government in its fight against money laundering activities and the criminal activities that lay beneath. Whistleblowers must however, be careful to follow all applicable rules and regulations in filing their whistleblower submission to ensure that they maximize the program's potential benefits and protections. 


Developing and Reporting your Information with Whistleblower Lawyers on your Side

If you have any information about a possible money laundering violation, it is important to report it to the authorities through the proper channels and following all required procedures. This is why it is important to have whistleblower lawyers on your side.

The U.S. Treasury Department is responsible for providing rewards to whistleblowers if the whistleblower’s non-public information about anti-money laundering violations leads to an enforcement action and the U.S. government collecting monies from the violator. For a whistleblower to be entitled to a reward under FinCEN’s whistleblower rewards program, the amount collected must exceed $1,000,000.

The whistleblower rewards program is a great way for individuals to come forward and report their inside information about some person or entity violating U.S. anti-money laundering laws.

If you have any non-public information about a person or entity violating U.S. anti-money laundering laws, it is best to contact a whistleblower attorney to help you file a claim for a reward. The whistleblower rewards program is still new, and there may be some uncertainties about how the program works. An experienced whistleblower attorney can help guide you through the process and maximize your chances of receiving a reward.

Remember, the U.S. government is offering rewards of up to 30% of the monies collected from the violator. The program is still new, so don’t wait to contact a whistleblower law firm like Piacentile, Stefanowski & Associates LLP, also known as Whistleblowers International, if you have any inside information about someone or something violating U.S. anti-money laundering laws.

Why should you choose us to help you fight against money laundering?

Finding a competent lawyer to help you report money laundering to the FinCEN is mandatory to maximize your award. Our team includes some of the most famous personalities in whistleblowing that will help you during the investigation and filing phases.

Take the first step

If you or someone you know has information about money laundering, our expert legal team will conduct a free case evaluation to help you better understand your legal options and what you can expect should you decide to file a whistleblower claim. 

If you delay in filing a claim it can weaken your case and reduce your potential reward, so we urge you to contact us by filling out a form or calling toll-free at (800) 689-8552. Your consultation is free and confidential.

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    Whistleblowers International exists to help whistleblowers with strong information and evidence of wrongdoing against the government bring whistleblower lawsuits, and ultimately to help the next generation avoid these experiences and to prevent future victims. That's what "Committed to Global Transparency" means to us.

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    We are familiar with the intricacies of these cases. You may not know exactly what kind of case your information might pertain to or what exact significance it has. We're the experts in this area and what to decipher that on your behalf. Whistleblower cases are extremely complex and your information may qualify you to initiate a legal action under one of the many kinds of governmental whistleblower programs that exist in the US.

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    There are many law firms that represent whistleblowers, but very few law firms keep whistleblower cases as their sole focus in the way that we do. We've done this for decades, and we are eager to speak with you.

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The information submitted will be submitted to the law firm of Piacentile, Stefanowski & Malherbe LLP d/b/a Whistleblowers International. This communication does not create an attorney-client relationship and is submitted only for the purpose of evaluating your claim to see if this is something we are able to help you with. By contacting us, you certify that you are a potential client making a bona fide inquiry about obtaining legal services to address a potential whistleblowing legal claim. Past results do not guarantee future outcomes. While this submission does not create an attorney-client relationship, all information submitted will be kept strictly confidential per legal ethics rules since this information is submitted in contemplation of a potential attorney-client relationship. No attorney-client relationship is formed until it is determined after evaluation with you that this is something we can take on and a retainer agreement is signed by you and the law firm of Piacentile, Stefanowski & Malherbe LLP d/b/a Whistleblowers International. Please also understand that by submitting your information, there is no guarantee that we will contact you in response, as at any given time, there are only a limited number of claims we are able to take on and pursue. If we do not contact you within 3-business days of your submission, please reach out to another whistleblower law firm if you are interested in pursuing your matter.