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Whistleblower Rewards for Reporting Sanctions Evasion

In the Anti-Money Laundering Whistleblower Improvement Act of 2022, Congress expanded the Anti-Money Laundering Act (AMLA) to require the Department of the Treasury to pay an award to a whistleblower for a voluntary disclosure of original information that results in the collection of penalties above $1 million for a violation of U.S. sanctions, in particular for a violation of:

  • the International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.);
  • sections 5 and 12 of the Trading With the Enemy Act (50 U.S.C. 4305; 4312); or
  • the Foreign Narcotics Kingpin Designation Act (21 U.S.C. 1901 et seq.).

A whistleblower who reports original information about sanctions evasion can obtain an award of 10% to 30% of the collected monetary sanctions.  Sanctions evasion whistleblowers can report anonymously if represented by an attorney.

Call us today to find out more about whistleblower incentives and protections and how we can help you report sanctions evasion and qualify for a whistleblowers.  You can contact us by phone or via WhatsApp or Signal at 202-930-5901 or 202-262-8959.

See our recent article Strengthened Enforcement of Sanctions Evasion Enhances Incentives for Sanctions Whistleblowers and the Whistleblower Lawyer’s Guide to the Anti-Money Laundering Whistleblower Program.

Reporting a Violation of U.S. Economic Sanctions Can Potentially Qualify for a Whistleblower Award Under AMLA or SEC Whistleblower Reward Programs

sanctions evasions whistleblower attorneysViolating U.S. economic sanctions can also violate disclosure duties under federal securities laws and therefore whistleblowing about sanctions evasion can qualify not only for an AMLA whistleblower award, but also for an SEC whistleblower award.
For example, Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 requires SEC-registered issuers to disclose all Iran-related activities covered by sanctions restrictions. The SEC’s Office of Global Security Risk (OSGC) monitors issuers’ disclosures related to business activities involving US-sanctioned counties.
And under Section 13(r) of the Exchange Act, issuers required to file Form 10-K, Annual Reports on Form 20-F and Quarterly Reports on Form 10-Q must disclose contracts, transactions and dealings with Iranian entities. Section 219 of the Iran Threat Reduction and Syria Human Rights Act added new Section 13(r) to the Exchange Act.
Recent Office of Foreign Assets Control penalties for sanctions violations have been substantial.  In March 2017, Zhongxing Telecommunications Equipment Corporation paid $100,871,266 in a settlement agreement for 251 apparent violations of the Iranian Transactions and Sanctions Regulations.  ZTE used third-party companies to surreptitiously supply Iran with a substantial volume of U.S.-origin goods, including controlled goods appearing on the Commerce Control List.

Guidance on OFAC’s Enforcement and Compliance Policies

Qualifying for an AMLA Sanctions Evasion Whistleblower Award

OFAC Sanctions Evasion Whistleblower Rewards Law Firm

The sanctions evasion whistleblower lawyers at Zuckerman Law have experience representing sanctions evasion whistleblowers and one of our attorneys is also a Certified Public Accountant and Certified Fraud Examiner.

Experienced and effective sanctions evasion whistleblower attorneys can provide critical guidance and effective advocacy to whistleblowers to increase the likelihood that they get the maximum award from the FinCEN Whistleblower Program.

U.S. News and Best Lawyers® have named Zuckerman Law a Tier 1 firm in Litigation – Labor and Employment in the Washington DC metropolitan area.

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For more information about sanctions evasion whistleblower rewards and bounties, contact the whistleblower lawyers at Zuckerman Law at 202-262-8959.

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