Anti-Money Laundering
Whistleblower Program

Overview

The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN)  administers the Anti-Money Laundering Whistleblower Reward Program, passed into law as part of the Anti-Money Laundering Act of 2020 (AMLA), program provides for mandatory awards to qualifying whistleblowers who provide information about violations of the Bank Secrecy Act (BSA), the principal law used by the Government to prosecute money laundering.  See 31 U.S.C. § 5323  The Anti-Money Laundering Reward program provides for awards of up to 30% of monetary sanctions imposed by the government based on whistleblower tips.  The Department of Justice may use whistleblowers’ information to bring civil, criminal or forfeiture actions against those who violate the BSA.

On Dec. 29, 2022, the Anti-Money Laundering Whistleblower Improvement Act (the “Whistleblower Improvement Act” or “Act”), amended the Bank Secrecy Act (BSA) to create a statutory minimum award (10%) and to expand the whistleblower program to cover violations of the International Emergency Economic Powers Act (IEEPA), the Trading with the Enemy Act (TWEA), and the Foreign Narcotics Kingpin Designation Act, which serve as the primary statutory authority for most U.S. economic sanctions.  The Office of Foreign Assets Control (OFAC) administers the economic sanctions programs.  The office has a list of countries with whom trade is restricted generally as well as a list of countries with whom certain transactions that threaten the security of the United States are prohibited. 

Requirements to Participate in the Program

FinCEN has not yet issued regulations governing its program. Contact our office for more details.