On December 29, 2022, Congress passed the “Anti-Money Laundering Whistleblower Improvement Act” to motivate both would-be whistleblowers and the plaintiffs’ bar to pursue Anti-Money Laundering Act of 2020 (“AMLA”) and related claims more vigorously by providing certain financial incentives. 

First, the Act entitles whistleblowers to an award of between 10 and 30 percent of the value of “monetary sanctions” above $1 million collected as a result of an enforcement action (importantly, “monetary sanctions” do not include forfeiture).  Second, the Act creates a “Financial Integrity Fund” to pay for whistleblower awards, which can hold up to $300 million.  The Department of Treasury can administer this fund independently of Congress, without the need for legislative appropriation. 

For additional information, please see the full Money Laundering Watch Alert prepared by our Ballard Anti-Money Laundering Team that regularly advises clients navigating these laws and developments.