Money Laundering, Sanctions & Corruption FinCEN & OFAC

Overview of the AML Whistleblower Program

The Anti-Money Laundering Act of 2020, as amended by the Consolidated Appropriations Act, 2023, established a whistleblower program that provides financial rewards and protections against retaliation for individuals reporting violations of the Bank Secrecy Act (BSA), an anti-money laundering law, and certain sanctions laws. Whistleblowers may report BSA violations to the Financial Crimes Enforcement Network (FinCEN), a bureau of the United States Department of the Treasury, and sanctions violations to the Office of Foreign Assets Control (OFAC), a Treasury agency. AML whistleblowers are eligible to receive between 10 to 30 percent of monetary sanctions recovered by Treasury in a covered judicial or administrative action exceeding $1 million.

Examples of BSA Violations

BSA violations that could serve as basis for an AML whistleblower report and award include:

Inadequate know your customer (KYC) verification process
Failures to file suspicious activity reports (SARS)
Ineffective training and enforcement of anti-money laundering compliance programs

Sanctions Violations Covered

Violations of the following sanctions laws may serve as basis for an AML whistleblower report and award:

The International Emergency Economic Powers Act
The Foreign Narcotics Kingpin Designation Act
The Trading with the Enemy Act

How to File a Tip

To learn more about filing a tip under the AML or Kleptocracy Whistleblower Programs, please see the following resources offered by our firm:

If you are considering reporting information concerning misconduct involving money laundering, sanctions, or corruption, please fill out our online form for a free confidential consultation.

Additional Whistleblower Resources

For other whistleblower programs, visit: