Other Money Laundering Fraud
In addition to the two areas of fraud most immediately covered by the FinCEN Whistleblower Program, there are other types of money laundering and sanctions violations that may be covered by different whistleblower programs. They may also be considered “related actions” to Bank Secrecy Act and/or sanctions violations, and thus may be wrapped up into another FinCEN whistleblower matter. Other whistleblower reward programs may also be available depending on the circumstances. For example, if the bad actor is regulated by the SEC, then a whistleblower may 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.
Some examples of other money laundering and sanctions frauds include:
Violating export control regulations and other restrictions on international trade.
Concealing beneficial ownership through 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 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.
These descriptions of the FinCEN Whistleblower Program are general in nature and do not constitute legal advice. Money laundering and sanctions violations are complex and ever-evolving. The attorneys at Whistleblower Partners understand the complicated, constantly changing legal landscape and are happy to discuss any potential matter further.
If you would like more information or would like to speak to an attorney at Whistleblower Partners, please contact us for a confidential consultation.