Anti-Money Laundering Whistleblowers

Enacted on January 1, 2021, the Anti-Money Laundering Act of 2020 (AMLA) is the most significant new anti-money laundering law since the 2001 Patriot Act.

The Anti-Money Laundering Act whistleblower program offers potentially stratospheric cash awards to whistleblowers who report illegal money laundering schemes and for individuals or entities evading sanctions.

Like SEC, IRS, CFTC, and Foreign Corrupt Practices Act whistleblower programs, the Anti-Money Laundering Act authorizes payments to anti-money laundering whistleblowers totaling up to 30% of any monies recovered in a successful settlement or verdict. With the support of an experienced anti-money laundering lawyer, money laundering whistleblowers can stay anonymous and maximize awards.

Authorizes payments to whistleblowers totaling up to 30% of any monies recovered in a settlement
Recent revisions to the AMLA have strengthened the award provisions for whistleblowers.

Specifically, whistleblowers are now entitled to a minimum amount of at least
10% of the sanctions collected as a result of a successful whistleblower’s tip.

Up to 30% Recovery for AML Whistleblowers

The AMLA amended the Bank Secrecy Act (BSA) 31 U.S.C. § 5323 to boost whistleblower protection and incentives.

The Anti-Money Laundering Act also doubled the maximum penalties for repeat BSA violators, increasing the available anti-money laundering whistleblower award amount. Today, money laundering enforcement actions can range from the hundreds of millions to billions of dollars. A $2 billion settlement amount could mean a $600 million check for the AMLA whistleblower if they play their cards right.

Under AMLA § 6314, whistleblowers whose information leads to a government recovery of over $1 million will collect a mandatory award of up to 30% of that recovery amount.

Victim restitution and forfeitures are not included in calculating reward amounts. However, all penalties, disgorgement, and interest are included.

A $2 billion settlement amount could mean a $600 million check for the AMLA whistleblower if they play their cards right.

$600 Million

Maximizing Anti-Money Laundering
Whistleblower Awards

AML whistleblowers who report illegal money laundering schemes using a strategic, informed approach can increase their award amount.

The AMLA whistleblower program is administered by the Treasury Department’s Financial Crimes Enforcement Network (FinCEN). As the AMLA is relatively new, it is hard to know precisely how the Treasury Department will calculate AML whistleblower award amounts.

But AML whistleblowers can increase the odds for a maximum
award by anticipating what the Treasury is looking for.

For example, under existing whistleblower programs, award calculations are based on the following criteria:

  • Timelines in reporting the violation
  • Hardships suffered by the whistleblower
  • Whistleblower’s involvement in wrongdoing
  • Whistleblower’s efforts to internally correct the violation before reporting

These same factors will play a role in calculating
AMLA whistleblower award amounts.

According to Congress, the Treasury should consider the following in determining AML whistleblower award amounts:

  • Significance of the whistleblower’s information to the success of the judicial or administrative action
  • Degree of whistleblower and whistleblower lawyer’s assistance in the investigation
  • Department of the Treasury’s programmatic interest in deterring similar violations as those exposed by the whistleblower
  • Other factors that the Department of Justice and the Treasury Department may later establish by regulation

Money Laundering and Sanctions
Whistleblower Reward Eligibility

Anti-money laundering and sanctions whistleblowers with original
knowledge of illegal money laundering schemes that rob the government of
at least $1 million may be eligible for the AMLA cash whistleblower award.

Examples of illegal money laundering schemes include:

  • Bank Money

    Financial institution owners use banks to clean dirty money. For example, a stock trading company owner moves dirty money from their company to another via currency exchanges.

  • Layering

    Putting dirty money through various layers of transactions and transfers overseas. This is common in cryptocurrency fraud and tax evasion schemes.

  • Cash Business
    Money Laundering

    Using businesses or starting a business for the purpose of cleaning dirty money.

  • Real Estate
    Money Laundering

    Buying real estate with dirty money, then rapidly selling the real estate to a third party and depositing the money from the sale in a valid bank account.

  • Trade-Based
    Money Laundering

    Disguising the movement of dirty money from one account to another as a trade transaction, often by multi-invoicing, over- or under-invoicing, or falsely representing goods and services.

  • Smurfing or Structuring

    Dividing dirty money up and depositing the smaller amounts into various accounts.

  • Gambling or Casino
    Money Laundering

    Dividing dirty money up and depositing the smaller amounts into various accounts.

While a $1 million minimum sanction seems like a lot, money laundering penalties and fines are commonly in the multimillions.

In addition to the $1 million requirement for AML whistleblower eligibility, the whistleblower must be the original source of information and must provide that information to Treasury, the Justice Department, or an employer by following a specific reporting process.

Non-U.S. citizen whistleblowers located anywhere in the world are eligible for anti-money laundering whistleblower rewards.

Auditors and compliance professionals may also be eligible for anti-money laundering whistleblower awards. In fact, the AMLA specifically defines the term whistleblower as:

“Any individual who provides… information relating to a violation… to the employer of the individual…, including as part of the job duties of the individual… or to the Secretary or the Attorney General.”

Those who are not eligible for AMLA whistleblower awards include bank regulators, law enforcement officials, and those criminally convicted for actions related to the violation. Making a false statement or report to authorities will also void any reward.

For a confidential (anonymous first call if you wish), no-cost evaluation to see if your information qualifies for the AMLA whistleblower program

Contact Katers & Granitz Today at 800.669.7782

Anti-Money Laundering Whistleblower Protections

Like the other whistleblower reward laws, employers are prohibited from retaliating against workers.

Under the Anti-Money Laundering Act:

“No employer may, directly or indirectly, discharge, demote, suspend, threaten, blacklist, harass, or in any other manner discriminate against a whistleblower in the terms and conditions of employment or post-employment because of any lawful act done by the whistleblower [in reporting AML violations].”

Victims of retaliation are entitled to job reinstatement, double
back pay with interest, attorney’s fees, and other damages.

AML Whistleblower Law Allows Anonymous Filing

Anti-money laundering whistleblowers need not disclose their identity, but
to remain anonymous, a whistleblower attorney must file their claim.

The AMLA also has strict confidentiality provisions to protect whistleblowers who wish
to remain anonymous and keep their identities confidential.

Other Anti-Money Laundering Whistleblower Programs

We have been representing financial services whistleblowers for many
years, including those who sought to report money laundering violations.

  • FIRREA Whistleblower Program
  • IRS Whistleblower Program
  • SEC Whistleblower Program

In addition to the AMLA, other whistleblower reward programs may
authorize awards for reporting money laundering, including:

Contact us to see if you have a case.

The anti-money laundering whistleblower lawyers at
Katers & Granitz are available now at

Expert Anti-Money Laundering Whistleblower Attorneys

Our experienced anti-money laundering whistleblower lawyers work
with you to package, enhance, and argue your anti-money laundering
claim for the largest possible cash award.

Our Katers & Granitz AML whistleblower legal team includes:

  • Ex SEC (Securities Exchange Commission) Chief of Investigations
  • Ex FDIC (Federal Deposit Insurance Corporation) Chief of Enforcement
  • Ex-Treasury Special Agent (offshore money laundering)
  • Ex OCC (Office of the Comptroller of the Currency) Special Counsel
  • Former Federal and State Prosecutors
  • Multiple CFE (Certified Fraud Examiners)
  • Former Senior Investigator in Bernie Madoff and R. Allen Stanford Ponzi Scheme prosecutions
  • Former government terrorist intelligence team leader (terrorist hunter)

AML Experience That No Legal Team Can Match

From real-world experience on the front lines of AML enforcement to
academia—teaching anti-fraud and AML topics in the University of
Maryland system, we wrote the book on AML.

Many law firms offer to take whistleblower cases. Most just “file and forget,” hoping the government takes over. Those lawyers don’t have the necessary experience to properly investigate and present anti-money laundering whistleblower cases.

We know precisely what prosecutors look for—preparing and delivering well-investigated, optimally presented, prosecution-ready cases. More importantly, we follow up and continue working on these cases long after filing a claim.

Anonymous Whistleblowers, Maximum Rewards

Ready to see if
you have a case?

Contact a Katers & Granitz anti-money
laundering whistleblower lawyer today at
800.669.7782 or connect online.

Anonymous initial calls are welcome.