New AML Whistleblower Law is A Game Changer in Enforcing Russian Sanctions

On December 29, the Anti-Money Laundering (AML) Whistleblower Improvement Act became law after Congress included the landmark anti-corruption bill in the Omnibus spending package. In a new article for Reuters, leading whistleblower attorney Stephen M. Kohn outlines how the AML Whistleblower Improvement Act will revolutionize the United States’s efforts to combat Russian corruption.

Kohn, a founding partner at Kohn, Kohn & Colapinto and Chairman of the Board of the National Whistleblower Center, played an instrumental role in the AML Whistleblower Improvement Act’s passage. The law offers mandatory monetary awards and anti-retaliation protections to individuals who blow the whistle on money laundering and sanctions violations.

“Although the AML Whistleblower Improvement Act broadly covers violations of both money laundering and sanctions requirements, the ability to use this law immediately to enforce all of the financial restrictions placed on Russia after the invasion of Ukraine was the driving force behind its passage,” writes Kohn.

In the article, Kohn overviews specific provisions of the law and notes that they are modeled on the whistleblower provisions of the Dodd-Frank Act, the law which established the highly successful SEC Whistleblower Program. Like Dodd-Frank, the AML Act’s whistleblower provisions apply to non-U.S. citizens, including whistleblowers located in Russia.

“The hidden gem within the AML Whistleblower Improvement Act is its ability to incentivize whistleblowers from inside Russia and Russia’s trading partners,” Kohn writes. “Given the law’s transnational reach, citizens from countries with financial or trade relations with Russia will have the ability to safely and effectively blow the whistle and help U.S. authorities seize sanctioned Russian wealth.”