Article by John Joy, Managing Attorney, FTI Law.
Sanctions are legal restrictions that prohibit U.S. persons and businesses from doing business with certain entities and in certain regions. Sanctions are enforced by the Department of Treasury and the Department of Justice (DOJ). Both agencies regularly issue fines to companies for violating sanctions and pursue violators aggressively. In addition, the Department of Treasury also offers incentives to those who report sanctions violations through its whistleblower rewards program.
If you want to report sanctions violations, here are the 5 steps to take:
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- Speak to a sanctions whistleblower lawyer (for free)
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- Determine if there is a sanctions violation
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- Preserve evidence of the violation
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- Decide where to report
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- Don’t delay in reporting
In this article, updated for 2025, we’ll talk you through each of these steps. If you have witnessed sanctions violations and want to figure out if you could claim a whistleblower reward for reporting it, take our anonymous online evaluation here.
1. Speak To A Sanctions Whistleblower Lawyer (For Free)
If you are thinking of reporting sanctions violations, it is critical that you speak with an experienced sanctions whistleblower lawyer. Reporting sanctions violations can expose you to retaliation or harassment. In addition, reporting in the wrong way or at the wrong time can severely affect your legal rights. A sanctions whistleblower attorney will be able to help you figure out whether there has been sanctions violations or what further information you need to make that determination. Additionally, if you decide to report a sanctions violation, your attorney can help you do it anonymously. Even if your employer offers a ‘confidential’ reporting channel or an anonymous ‘whistleblower hotline,’ there is no substitute for an attorney reporting on your behalf. FTI Law offers free consultations that are completely confidential. Speaking to an attorney will cost you nothing, and could help you keep your job while reporting or even claim a whistleblower reward. To speak to a sanctions whistleblower attorneys now, simply contact FTI Law here.
2. Determine If There Has Been A Sanctions Violation
Sanctions have limited application, meaning they do not apply to every person and company in the world. If you want to report a violation, you need to figure out if the perpetrator of the violation is subject to sanctions, meaning you have to be sure that the perpetrator is required to abide by sanctions. In general, sanctions apply to all U.S. companies and individuals, and some foreign companies.
After confirming the company or person you wish to report is subject to sanctions, you will need to learn the basic elements of a sanctions violation and check if the conduct you have witnessed meets all those elements. A common sanctions violation is doing business or purchasing from a region or country that is subject to sanctions, such as:
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- Iran
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- Cuba
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- North Korea
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- Russia
If you want to learn more about the sanctions affecting these regions, you can check out the sanctions guide published by the Office of Foreign Asset Control (OFAC). Once you have determined that there may be a sanctions violation, you should contact us.
3. Preserve Evidence Of the Violation
If you want to report a sanctions violation effectively you should think about whether you can provide documents, emails or other evidence to support claim. This will help convince the DOJ and OFAC to investigate the violation and put an end to the misconduct. However, it is also important that you do not obtain evidence illegally, such as by accessing other people’s property or devices without their permission. When figuring out what evidence to gather, your attorney will be able to advise what it is safe to collect and what it is not. Even if your employer has made you sign an Non-Disclosure Agreement (NDA), you are always entitled to speak to your attorney about these issues without breaching the NDA.
4. Decide Where To Report First
When reporting a sanctions violation, you may be entitled to legal protection from retaliation and a whistleblower award for reporting. However, whether you receive these benefits depends on where you report the violation. For example, certain U.S. laws provide protections for individuals who report sanctions violations to federal regulators. However, some of those protections do not apply if the person only reports to their employer. Similarly, if you report sanctions violations to OFAC, you could be entitled to a sanctions whistleblower reward.
5. Don’t Delay In Reporting
Both the DOJ and OFAC have limitations on how and when they can prosecute sanctions violations. For certain violations, this could be as short as 5 years, and an investigation could take 2-3 years. If you want the DOJ and OFAC to investigate the violation, you need to give them as much time as possible by reporting early. If you want to claim a whistleblower award this is especially important, as if someone reports the same information you have before you, they will get the whistleblower award and you won’t. In addition, even if you qualify for a reward, the amount can be reduced if a person delays reporting.
About the Author
John Joy is the Managing Attorney and founder of FTI Law, a law firm that focuses on representing FCPA whistleblowers, sanctions whistleblowers and money laundering whistleblowers. John is a New York whistleblower attorney who has worked for almost a decade on FCPA and sanctions cases. Prior to founding FTI Law, John worked at an elite international law firm in New York and London representing clients in multi-national investigations before the DOJ, SEC, FINRA, OFAC, the FCA & SFO. John is one of the few whistleblower attorneys with extensive international experience working with Fortune 500 corporations who are often the subject of whistleblower complaints.
