Belarus-Related Sanctions and Whistleblower Rewards

It may be in your and the U.S. government’s interest to authorize economic activity related to the Belarus Sanctions. Certain activities related to the Belarus Sanctions may be allowed if they are licensed by OFAC. General licenses allow all U.S. persons to engage in the activity described in the general license without needing to apply for a specific license.

• General License 8 – Authorizing the Wind Down of Transactions Involving Joint Stock Company Byelorussian Steel Works Management Company of Holding Byelorussian Metallurgical Company (August 09, 2023)
• General License 9 – Authorizing Transactions Related to Civil Aviation Safety or the Wind Down of Transactions Involving Open Joint Stock Company Belavia Belarusian Airlines (August 09, 2023)
• General License 10 – Authorizing the Wind Down of Transactions Involving Tabak Invest LLC (December 05, 2023)

Under AML law, whistleblowers can report violations of Belarus-related sanctions to the Office of Foreign Assets Control (OFAC), if they can they provide information regarding an individual, company, or country engaging in the following activities with sanctioned individuals or organizations from Belarus:

• Evading sanctions: Activities that attempt to circumvent or bypass US sanctions.
• Sanctions violations: Actions that violate specific terms of US sanctions programs.
• Fraudulent activity: Misrepresentation or deception related to US sanctions.

An example of a Belarus-related sanctions violation might include the improper use of General Licenses (listed above). Violations might also include the use of cryptocurrency exchanges to carry out illegal financial transactions, especially those that support undemocratic elections or corruption by government officials.

New AML laws offer significant rewards for whistleblowers reporting sanctions violations in Belarus. Whistleblowers can receive 10-30% of the penalties collected if their tip leads to successful enforcement action.

This financial incentive encourages reporting and collaboration with law enforcement to secure convictions. However, it’s important to note that rewards are contingent on success, and there’s no payout if the case falls through. Additionally, whistleblower protections might not extend to non-U.S. citizens, leaving them vulnerable to retaliation.

Despite these limitations, the potential reward can be a powerful motivator. If you suspect sanctions violations, report them through the proper channels to ensure investigation and enforcement. While anonymity and confidentiality are options under AML laws, you’ll need a U.S. attorney to facilitate the anonymous reporting process.

Sanctions regulations, especially those related to Belarus, can be a legal labyrinth. That’s where our expertise comes in. Our firm played a pivotal role in securing the passage of the Anti-Money Laundering Improvement Act – a testament to our deep understanding of these intricate regulations.

Since 1988, we’ve championed whistleblowers in some of history’s biggest cases. We leverage this experience to empower you with the knowledge and legal muscle needed to expose potential violations, including Belarus-related sanctions, Bank Secrecy Act breaches, and sanctions evasion attempts.

If you suspect a violation, contact us today for a free and confidential case review.