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US Bill to Offer Rewards for Whistleblowers Exposing Money Laundering

Posted  January 29, 2021

Partner Mary Inman was quoted in the OCCRP article, “US Bill to Offer Rewards for Whistleblowers Exposing Money Laundering”, published on January 18, 2021.

Treasury’s new whistleblower reward program is inspired by the highly successful U.S. Securities and Exchange Commission (SEC) Whistleblower Reward Program created by the Dodd-Frank Wall Street Reform and Consumer Protection Act following the 2008 financial crisis. Under the new program, Treasury can incentivize the US and international whistleblowers who expose money laundering by offering up to 30% of the monetary sanctions collected from wrongdoers provided they exceed $1,000,000. Though, unlike the SEC’s program, which provides for mandatory rewards of between 10 to 30 % of any fine that is ultimately collected, the new anti-money laundering program rewards are paid out at the discretion of the Treasury without any minimum award.

While discussing the need to incentivize whistleblowers in the fight against transnational crimes, Inman noted the new program’s potential as a “real game-changer in anti-money laundering enforcement” anticipating “a ripple effect,” where other countries, including European Union countries, could adopt similar programs.

  • “There is a growing consensus that [rewards] serve as an essential insurance mechanism for whistleblowers that assume tremendous risk in bringing forth evidence, oftentimes against their own employer.”
  • When discussing the lack of any logic behind the failure to provide a minimum award range, Inman noted: “In the enacting regulations, that would be something that would need to be addressed first and foremost.”
  • “Money laundering is really hard to detect,” and, in making it as seamless as possible for whistleblowers to provide evidence, the proposed law would allow investigators more chances to get “the silver bullet that it needs, but often can’t get.”

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Tagged in: Financial and Investment Fraud, Financial Institution Fraud, International Whistleblowers, Money Laundering, SEC Whistleblower Reward Program, Whistleblower Rewards,