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U.S. Senate Unanimously Passes AML Whistleblower Improvement Act


On December 7, 2022, the U.S. Senate voted unanimously to expand whistleblower incentives and strengthen whistleblower protections by passing the Anti-Money Laundering Whistleblower Improvement Act.

The bill would bolster the anti-money laundering whistleblower program by adding support for whistleblowers who report violations of U.S. sanctions laws, guaranteeing that whistleblowers will be paid a minimum award amount, and providing a funding mechanism to pay whistleblower awards.  Specifically, the proposed legislation:

  • Enables whistleblowers who disclose a violation of the International Emergency Economic Powers Act, the Foreign Narcotics Kingpin Designation Act, and/or the Trading with the Enemy Act that leads to a successful enforcement action;
  • Entitles whistleblowers to an award of between 10 and 30 percent of the value of fines collected as a result; and
  • Creates a $300 million fund to pay whistleblower awards from fines collected by the Justice and Treasury Departments.

In announcing the passage of the bill, Senator Chuck Grassley, one of the bill’s co-sponsors (along with Senators Raphael Warnock, Elizabeth Warren, and Catherine Cortez Masto), noted that “with the False Claims Act saving taxpayers $70 billion, the SEC whistleblower program saving over $4.8 billion and the IRS whistleblower program saving over $6 billion[,] I’m optimistic that our new program encouraging individuals to come forward for suspected sanctions violations will be successful as well.”  Senator Grassley further explained that “[g]iven 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.”

If signed into law, this legislation could significantly expand the potential monetary rewards available to whistleblowers under the AMLA, further incentivizing whistleblowers to report potential violations of the sanctions laws.

The bill is now before the House.  We will continue to track the developments in the House and will keep our readers informed of any future developments.


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