Sanctions Evasion Whistleblower
We Help Whistleblowers Report Sanctions Evasion to the U.S. Treasury Department or the U.S. Department of Justice (DOJ)
Violations of U.S. Office of Foreign Assets Control (OFAC) sanctions can expose financial institutions and other parties to substantial civil penalties (and criminal penalties in some cases). If you have information about a violation of U.S. sanctions laws, you may be eligible to serve as a sanctions evasion whistleblower. Our lawyers can help you make an informed decision about coming forward.
The U.S. Office of Foreign Assets Control (OFAC) administers multiple sanctions programs designed to prevent money laundering through the U.S. financial system. These sanctions are strictly enforced, and sanctions violations can trigger steep penalties.
However, federal authorities rely heavily on whistleblowers to come forward.
While OFAC administers the federal anti-money laundering sanctions programs, the U.S. Treasury Department and U.S. Department of Justice (DOJ) have primary responsibility for sanctions enforcement. Both of these federal departments work closely with whistleblowers, and they provide incentives for whistleblowers to report violations when warranted.
Reporting OFAC Sanctions Violations Under the Bank Secrecy Act (BSA) and Anti-Money Laundering Act (AMLA)
Our lawyers help whistleblowers report sanctions violations to the Treasury Department and DOJ when warranted. We assist with reporting violations by sanctioned entities, financial institutions, and other entities. This includes reporting sanctions violations that implicate the following federal statutes:
- Bank Secrecy Act (BSA)
- Anti-Money Laundering Act (AMLA)
- International Emergency Economic Powers Act (IEEPA)
- National Defense Authorization Act (NDAA)
- Trading with the Enemy Act (TWEA)
From a sanctioned entity directly violating OFAC sanctions to a financial institution or company allowing sanctioned entities to transact business using its platform, violations can take numerous forms, and this means that filing a whistleblower claim can be warranted in a wide range of circumstances.
Serving as an Anti-Money Laundering (AML) Whistleblower
Sanctions evasion and anti-money laundering (AML) violations tend to go hand-in-hand. As a result, exposing sanctions evasion will involve serving as an AML whistleblower in many cases.
Our AML whistleblower attorneys help individuals come forward when warranted, providing legal representation at no out-of-pocket cost. We have extensive experience with the federal AML whistleblower program and its implementing regulations, and we are intimately familiar with whistleblowers’ disclosure duties, the government’s duty to protect a whistleblower’s information, and the circumstances in which monetary awards are available.
Preparing to Expose Sanctions Evasion Under the AML Whistleblower Program
If you are interested in serving as a sanctions evasion whistleblower, what do you need to know? Here are some key insights:
Serving as a Sanctions Evasion Whistleblower Requires Independent Knowledge of Illegal Conduct
To qualify as a sanctions evasion whistleblower, you must be able to come forward with information about illegal conduct that is based on independent knowledge. This is a requirement under the whistleblower provisions of the BSA and AMLA, among other federal whistleblower laws. If you have information about unlawful conduct by a sanctioned entity (including a sanctioned country); efforts to bypass trade restrictions; efforts to facilitate terrorist financing; other threats to national security; or any other AMLA, IEEPA, NDAA, TWEA, or BSA violations, our lawyers can assess your eligibility to come forward.
Requests to Violate the Law
Employers cannot ask their employees to violate the law. Under no circumstances does violating the law fall within an employee’s duties. If someone with supervisory authority asked you or a coworker to violate the law, this is a serious matter that warrants speaking with a railroad whistleblower attorney. From requests to overlook safety violations to requests to overlook the misuse of federal funds, all types of requests can serve as grounds for whistleblower claims under the FRSA.
Whistleblowers Must Timely Come Forward Through the Appropriate Channels
As a general rule, whistleblowers must also be the first to come forward in order to qualify for the protections (and compensation) that are available. With this in mind, if you think you may be prepared to voluntarily provide information to the federal government as a sanctions whistleblower, we strongly recommend consulting with an experienced whistleblower lawyer as soon as possible.
The BSA and AMLA Include Whistleblower Protection Provisions
Individuals who report money laundering, sanctions violations, and other statutory and regulatory violations under the BSA and AMLA (among other federal statutes) are entitled to strong whistleblower protections—provided that they come forward appropriately. These include both strong confidentiality protections and protections against retaliation.
The DOJ and Treasury’s Office of Inspector General Are Required to Protect a Whistleblower’s Identity
The DOJ, the Treasury’s Office of Inspector General, and other federal law enforcement agencies have a duty to protect whistleblowers’ identities. Additionally, as your legal representatives, we will have a strict duty to protect your confidentiality, and we will not disclose any information you share with us to the federal government unless you authorize us to do so.
Whistleblower Rewards Are Available in Some Cases
When whistleblower complaints lead to successful enforcement actions, whistleblowers will often be entitled to a financial reward calculated as a percentage of the monetary sanctions (or other monetary penalties) recovered. The DOJ and Treasury Department both pay awards to eligible whistleblowers in appropriate cases (when penalties exceed $1 million), and awards typically range from 10% to 30% of the amount recovered. To seek an award, you must come forward through one of the DOJ’s whistleblower programs or the whistleblower reward program administered by the Treasury Department’s Financial Crimes Enforcement Network (FinCEN).
This does not constitute legal advice. If you have questions about serving as a sanctions evasion whistleblower, we strongly encourage you to get in touch. Once we learn about the specific information you have in your possession, we can advise you regarding the options you have available.
What You Can Expect from Our Sanctions Evasion Whistleblower Lawyers
If you contact our law firm, what can you expect going forward? Here is what you can expect from our team of experienced sanctions evasion whistleblower lawyers:
- We Will Assess Your Situation and Explain Your Options – After thoroughly assessing your situation, we will be able to explain the options you have available.
- We Will Help You Make Informed Decisions – Our lawyers will answer all of your questions and provide the insights you need to feel confident in your next steps.
- We Will Help You Establish Your Status as a Protected Whistleblower – If you decide to report a violation of a U.S. sanctions program or the Bank Secrecy Act to the DOJ or FinCEN, we will assist with establishing your status as a protected whistleblower.
- We Will Work with the Federal Government on Your Behalf – If you decide to come forward, we will directly represent you in all communications with the federal government.
- We Will Assist with Securing Your Whistleblower Reward (if Applicable) – If you decide to come forward and you become eligible to receive a whistleblower reward, we will assist with securing your reward from the federal government.
FAQs: Coming Forward as an Anti-Money Laundering Whistleblower to Report Sanctions Evasion
What are the requirements for seeking an AML whistleblower award when reporting sanctions evasion?
To seek an AML whistleblower reward when reporting sanctions evasion, you must provide original information based on independent knowledge, and you must generally be the first to come forward. Our attorneys can assist with determining your eligibility and then guide you through the process of coming forward if you decide to blow the whistle.
Do I need an AML whistleblower lawyer to report sanctions evasion?
While not legally required, hiring a lawyer to help you report sanctions evasion is strongly recommended. Coming forward as an AML/BSA whistleblower is a complex process that requires an in-depth understanding of all relevant federal laws and regulations. It does not cost anything out-of-pocket to hire a lawyer in this scenario.
Is there a minimum reward for reporting sanctions evasion?
Under FinCEN’s whistleblower reward program, eligible whistleblowers are entitled to a minimum of 10% of the government’s recovery in successful cases. Since rewards are only available in cases involving the recovery of $1 million or more, this effectively means that the minimum reward for reporting sanctions evasion (in eligible cases) is $100,000. However, whistleblower rewards can also be far greater in many cases.
What if my job duties include preventing or reporting sanctions evasion?
Even if your job duties include preventing or reporting sanctions evasion, you may still be eligible to serve as a sanctions evasion whistleblower. If you have questions about your eligibility to serve as a whistleblower, our lawyers can explain everything you need to know. We have extensive experience in this area, and our whistleblower team includes lawyers who prosecuted BSA/AML cases at the DOJ before entering private practice.
How can I obtain further information about reporting sanctions evasion to the federal government?
If you would like more information about reporting sanctions evasion to the federal government, we strongly encourage you to contact us for a free and confidential consultation. Our lawyers represent sanctions evasion whistleblowers throughout the United States and worldwide. We can explain everything you need to know in order to make informed and confident decisions; and, if you decide to come forward, we can advise and represent you every step of the way.
Schedule a Free and Confidential Consultation with a Sanctions Evasion Whistleblower Lawyer
To discuss your options for coming forward with an experienced sanctions evasion whistleblower lawyer, contact us today. To arrange a free, no-obligation consultation with one of our senior lawyers as soon as possible, call us at 866-320-3959 or contact us confidentially online now.