Filing an Anonymous AML/Money Laundering Complaint

If you have information about a potential money laundering case, you may be eligible to file an anonymous claim. However, the law requires that a licensed attorney file the anonymous claim on your behalf.
When working with an attorney, they should provide the following information: their name, complete address including city, state and zip code, telephone number and if available an alternate number where they can be reached, email address and preferred method of communication.
The claim should be filed with FinCEN, the Financial Crimes Enforcement Network. The email address to use is FRC@fincen.gov and should be directed to the Whistleblower Office/Nell Williams.
How to File an Anonymous Complaint Regarding Violation of Sanctions
If you have information about a violation of sanctions, you have the option to file an anonymous complaint. However, the law requires that a licensed attorney file the claim on your behalf. This includes sanctions imposed by the U.S. on countries such as Russia, Cuba, Iran and North Korea.
When filing an anonymous complaint, your attorney should provide the following information: their name, complete address (including city, state and zip code), telephone number and an alternate number where they can be reached, e-mail address and preferred method of communication.
The complaint should be filed with FinCEN, the Financial Crimes Enforcement Network. The email address to use is FRC@ficen.gov, and the email should be directed to the Whistleblower Office/Nell Williams.
What to include in your AML/Money Laundering Whistleblower Claims
When submitting a complaint to the FinCEN Office of the Whistleblower, it is important to make sure that your disclosure is detailed, organized, and complete. FinCEN wants as much information as possible to help them investigate the complaint.
In order to identify the targets of the potential investigation, you should provide information about the entity or individual you are complaining about, including their type of entity, profession, and contact information. You may also want to consult Title 31, Part X of the Code of Federal Regulations for information about entities covered under the law.
FinCEN does not have set rules for what type of information is particularly helpful in their review of your claim, but they suggest providing a timeline, whether the conduct or violations are still ongoing, a description of all facts relevant to the alleged violations, why you believe these facts constitute violations of the Bank Secrecy Act or regulations administered by FinCEN, how you obtained the information that supports your allegations, names and contact information regarding other witnesses or key databases, your relationship with the subject of the complaint, and any other information you believe to be relevant.
You may also submit documents or other data to back up your case, including a description of all supporting materials and evidence in your possession that support the allegations. These documents can be emailed to FinCEN or provided through an FTP link for them to download. If you believe that any information or documents in your complaint could reasonably reveal your identity, you should specifically describe this in your submission.
Additionally, if you believe that any information or documents in your complaint may be subject to a privilege, you should describe this in your submission and segregate it from the rest of the materials provided. FinCEN does not want you to initially provide them with documents that you believe are privileged materials.
Our Firm’s Cases
On September 19, 2018, news broke of $234 billion money laundering scheme. The scheme moved rubbles out of Russia, converted them to dollars at the Estonian branch of Danske Bank, and then moved the dollars to New York with the assistance of three correspondent banks (Bank of America, J.P Morgan, and Deutsche Bank). Danske Bank admitted all of its internal controls designed to prevent money laundering had failed. The bank also revealed that the scheme had been reported to the highest levels of the bank by a whistleblower over four years before. The whistleblower’s identity was required to be secret. But it took only days for his name to leak out. Soon the entire international banking world learned that the former Danske Bank manager Howard Wilkinson had exposed the largest money laundering scheme in history, and that the bank had tried to cover it up.
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This piece originally appeared in JD Supra. A two-year campaign to create an effective law incentivizing whistleblowers to report money laundering and sanctions busting has ended with a stunning and surprise victory for whistleblowers. It started in December 2020 when Congress released the Conference Committee report on the National Defense Authorization Act ...
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On December 23, Congress passed the Anti-Money Laundering (AML) Whistleblower Improvement Act. The Act establishes an effective whistleblower program covering individuals disclosing both money laundering and sanctions-busting violations. Given its transnational reach, it promises to revolutionize the United States’ global anti-corruption efforts. “This law is the most important transnational anti-corruption law ...

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