Question of the Week — Is it Time for an Anti-Money Laundering Whistleblower Program?
Current US law includes a variety of whistleblower programs that reward private persons for bringing information to the government. The programs range widely, and include everything from the False Claims Act (which rewards whistleblowers for revealing fraud against the government) to the SEC whistleblower program (rewards for reporting violations of US securities laws) to the Act to Prevent Pollution from Ships (rewards for reporting unlawful dumping of waste into the Oceans). However, there is no program that broadly issues rewards in exchange for information about money laundering.
Anyone who has been paying attention to the news in the last few years is certainly aware of a series of massive, global scandals that revolved around money laundering. In 2016, a whistleblower lead to the publication of the “Panama Papers” leak and revealed that various wealthy and powerful individuals, as well as some corporate entities, were involved in tax evasion, arms deals, drug trafficking, and other criminal actions. The next year, another whistleblower lead to the “Paradise Papers” leak revealing even more secrets of how the world’s elites transfer money around the globe to avoid taxes and, in some instances, participate in alleged criminal activity. And just last month, yet another whistleblower revealed billions of dollars may have been laundered through a single branch of Danske Bank in Estonia.
To get a reward, all of these whistleblowers might try using the IRS Whistleblower Program, but would need to their allegations to a specific violation of an American tax law and would likely not be rewarded for general information about criminal activity that does not affect tax evasion directly.
What do you think? Given the well documented ties between money laundering and crime, should there be a rewards program for whistleblowers who provide information about money laundering?