FinCEN Whistleblower Program

Here’s What to Know About FinCEN’s Anti-Money Laundering and Sanctions Whistleblower Program

The Financial Crimes Enforcement Network (FinCEN) is actively accepting cases under its Anti-Money Laundering and Sanctions Whistleblower Program (commonly referred to as the “AML Whistleblower Program” or simply the “AML Program”). FinCEN issued regulations to finalize the award provisions of the AML Program in 2026, and it is actively encouraging individuals to report anti-money laundering violations and disclose information about other violations of federal law.

If you are interested in coming forward under FinCEN’s AML Whistleblower Program, we strongly encourage you to get in touch. Our whistleblower attorneys work with individuals in the U.S. and worldwide who are eligible to submit information to FinCEN. Under the terms of the AML Program, when a whistleblower’s information leads to a successful enforcement action resulting in monetary penalties exceeding $1 million, the whistleblower is entitled to a monetary award of 10% to 30% of the amount recovered.  

FinCEN Whistleblowers Can Report Wrongdoing By Financial Institutions and Other Entities and Individuals

Under the FinCEN whistleblower program, eligible individuals can submit whistleblower tips involving wrongdoing by financial institutions and other entities and individuals. At Oberheiden P.C., our attorneys assist eligible whistleblowers with reporting statutory and regulatory violations committed by entities including (but not limited to):

• Banks and other financial institutions
• Corporate entities and partnerships
• Cryptocurrency exchanges
• Investment firms, brokerage firms, and mutual funds
• Money services businesses

These are just examples. FinCEN has oversight of entities and individuals involved in all facets of the U.S. financial system, and it enforces U.S. anti-money laundering (AML) and sanctions laws domestically and abroad. Our attorneys work with both domestic and international whistleblowers, including (but not limited to) current and former employees of the entities listed above.

FinCEN Whistleblowers Can Report Bank Secrecy Act (BSA) Violations Among Many Others

Current employees, former employees, and other individuals can report a wide range of statutory and regulatory violations under the FinCEN whistleblower program. This includes (but is not limited to) violations of the following statutes and their implementing regulations:

• Anti-Money Laundering Act (AML Act)
• Bank Secrecy Act (BSA)
• Foreign Corrupt Practices Act (FCPA)
• International Emergency Economic Powers Act (IEEPA)
• Trading with the Enemy Act (TWEA)

FinCEN enforces strict compliance with these (and other) sources of federal authority, and violations can expose entities and individuals to both civil monetary sanctions and criminal penalties. Our whistleblower attorneys help eligible individuals report all civil and criminal violations falling within FinCEN’s enforcement jurisdiction, including common violations such as:

• Anti-money laundering (AML) violations
• Facilitating transactions that involve terrorist financing
• Failure to properly prepare or file currency transaction reports (CTRs) to report large cash transactions
• Failure to properly prepare or file suspicious activity reports (SARs)
• Foreign bank account disclosure violations
• Office of Foreign Assets Control (OFAC) sanctions violations (i.e., conducting financial transactions with a sanctioned entity)
• Public corruption and bribery

From failure to properly retain SAR information and other compliance failures to intentional legal violations that compromise national security, FinCEN whistleblowers can—and should—expose all forms of wrongdoing. If you are eligible to serve as a FinCEN whistleblower, our attorneys can file your complaint and work with FinCEN on your behalf throughout the investigation process.

Filing a Complaint Under FinCEN’s AML Whistleblower Program

Like all government whistleblower programs, there are both substantive and procedural requirements for coming forward under FinCEN’s AML whistleblower program. When you engage our FinCEN whistleblower lawyers to represent you, our lawyers will assist you with meeting all of these requirements.

Specifically, as your legal counsel, we will:

1. Confirm Whether the Information You Have in Your Possession is Sufficient to File a Whistleblower Complaint with FinCEN

The information that you are prepared to disclose to FinCEN must be sufficient to warrant opening a federal investigation. Our attorneys can confirm whether the information that you have in your possession is sufficient to meet this requirement.

2. Engage with FinCEN to Determine Whether an Existing Investigation is Underway

To qualify as a whistleblower, you must be able to provide “original information” that warrants opening a new information (or, in limited circumstances, that significantly contributes to an existing investigation). Our attorneys can engage with FinCEN to find out whether an investigation is already underway.

3. File Your Complaint In Accordance with the Requirements of FinCEN’s Whistleblower Program

If you are eligible to serve as a FinCEN whistleblower, our attorneys can file your complaint in accordance with the substantive and procedural requirements of FinCEN’s whistleblower program. This is a necessary step for securing both protection and reward eligibility as a whistleblower.

4. Work Directly with FinCEN On Your Behalf During Its Investigation

Once we file your whistleblower complaint, our attorneys will work directly with FinCEN on your behalf during its investigation. As we do so, we will remain in close contact with you as well, and we will help you make informed and confident decisions throughout the process.

5. Work Directly with Other Federal Authorities as Warranted

In some cases, other federal agencies may have an interest in pursuing cases involving AML/BSA and sanctions violations as well. Our attorneys can also work with the Internal Revenue Service (IRS), U.S. Commodity Futures Trading Commission (CFTC), U.S. Treasury Department (Treasury), the Treasury’s Office of Foreign Assets Control (OFAC), U.S. Attorney General’s Office, and other federal authorities on your behalf as warranted.

Eligibility for FinCEN Whistleblower Awards

FinCEN’s Anti-Money Laundering and Sanctions Whistleblower Program is one of a handful of federal whistleblower programs that includes provisions for whistleblower compensation. As noted above, whistleblowers who help FinCEN recover civil or criminal sanctions are entitled to rewards ranging from 10% to 30% of the amount recovered in excess of $1 million.

If you become eligible for a reward after disclosing a violation of the Anti-Money Laundering Act (AML Act), Bank Secrecy Act (BSA), or any other federal statute to FinCEN, our attorneys can work with FinCEN to secure an appropriate reward on your behalf. Our attorneys can emphasize your role in helping FinCEN pursue a successful enforcement action, and then we can assist with collecting your reward from the federal government.

FAQs: Blowing the Whistle with the Financial Crimes Enforcement Network (FinCEN)

Need to Know More About FinCEN’s Whistleblower Program? Schedule a Free Initial Consultation Today

If you would like more information about FinCEN’s whistleblower program, we invite you to schedule a free initial consultation at Oberheiden P.C. To speak with one of our senior federal whistleblower attorneys in strict confidence as soon as possible, please call 888-680-1745 or tell us how we can contact you online now.

Further Information About Our FinCEN Whistleblower Lawyer Services

• FinCEN Whistleblower Lawyers
• Who Can Serve as a FinCEN Whistleblower?
• Do I Need to Hire a FinCEN Whistleblower Attorney?
• FinCEN Whistleblower Award