Revealing Other Kinds of Money Laundering, Sanctions Violations, and Related Fraud With Experienced Attorneys

In addition to the two areas of fraud most immediately covered by the FinCEN Whistleblower Program, there are other types of money laundering and related violations that may be covered by different whistleblower programs. The Department of Justice (DOJ) has a Corporate Whistleblower Awards Pilot Program that covers all money laundering and sanctions evasion violations that are not otherwise covered by FinCEN and that result in criminal forfeiture, that is, having to give up the ill-gotten gains a corporation makes from its bad acts. Other programs may also be available depending on the circumstances. For example, if the bad actor is regulated by the SEC, then a whistleblower may be able to submit a claim under the SEC Whistleblower Program. Similarly, if the bad actor is regulated by the CFTC, a whistleblower may submit a tip under the CFTC Whistleblower Program. Whistleblowers can submit tips to multiple programs. And because the FinCEN Whistleblower Program allows a whistleblower to recover for “related actions” as long as DOJ or the Department of the Treasury recovers at least $1 million, a FinCEN whistleblower may be able to recover for other money-laundering activity if it is tied to a Bank Secrecy Act violation.

Some Examples of Other Money Laundering and Related Violations Include:

• Violating export control regulations and other restrictions on international trade.
• Concealing beneficial ownership through the use of anonymous shell companies with no real operations or nominee accounts to avoid legal regulation.
• Using offshore accounts in secrecy jurisdictions to hide transactions or ownership and thus evade regulation.
• Structuring transactions to break up large amounts of money into multiple smaller transactions to avoid detection.
• Using cryptocurrency or fiat currency to pay for illegal goods and services.
• Setting up offshore accounts to funnel U.S. profits to shell corporations and evade tax obligations.
• Putting ill-gotten gains into a legitimate business to “wash” the dirty money by mixing it with legitimate profits.