Why FinCEN Should Quickly Establish Regulations for the New AML Whistleblower Program

The nascent AML whistleblower program promises to boost enforcement in a difficult area, but FinCEN must swiftly develop regulations to ensure that it launches the program in the most robust way possible. Created by the Anti-Money Laundering Act of 2020 (AMLA), passed as part of the FY21 National Defense Authorization Act (NDAA), the program went into immediate effect.  Motivated by retaliation protections and the potential for rewards, whistleblowers ready to...

Project Proposes Legislative Action to Protect and Incentivize AML Whistleblowers

Offshore Alert and the Association of Certified Financial Crime Specialists were joined by Constantine Cannon Whistleblower Lawyers Poppy Alexander, Eric Havian, and Michael Ronickher in developing a proposal to enact legislation that would create statutory incentives and protections for whistleblowers with information about money laundering. The proposal, unveiled on May 25, 2020, was developed in response to a challenge in the FT Innovative Lawyers Global Legal Hackathon to figure out ways...

Constantine Cannon Submits Comments to Proposed Rulemaking for FinCEN AML/Sanctions Whistleblower Program

By the Constantine Cannon Whistleblower Team As we previously reported, two months ago the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a press release announcing its Notice of Proposed Rulemaking “to fully implement” FinCEN’s AML/Sanctions Whistleblower Program. What is the FinCEN AML/Sanctions Whistleblower Program? Congress established the FinCEN Whistleblower Program in 2021 (expanding it in 2022) to provide financial rewards and protections to whistleblowers reporting anti-money laundering (AML) violations under the Bank...

FinCEN Moves Another Step Closer to Issuing Its First Award Under Its AML/Sanctions Whistleblower Program

 By the Constantine Cannon Whistleblower Team On Monday (March 30), the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a press release announcing its Notice of Proposed Rulemaking “to fully implement” FinCEN’s AML/Sanctions Whistleblower Program.[1] What is the FinCEN AML/Sanctions Whistleblower Program? This is the whistleblower program Congress established in 2021 (and expanded in 2022) that rewards whistleblowers for reporting anti-money laundering (AML) violations under the Bank Secrecy Act (BSA) and sanctions...

Calling All AML/Sanctions Whistleblowers -- FinCEN Wants to Hear From You

By the Constantine Cannon Whistleblower Team Two weeks ago (on February 13), the Treasury Department announced that its Financial Crimes Enforcement Network (FinCEN) has “launched a new dedicated webpage to confidentially accept whistleblower tips on fraud, money laundering, and sanctions violations.”[1] What Is the AML/Sanctions Whistleblower Program? The dedicated site is the latest development of FinCEN’s AML/Sanctions Whistleblower Program which Congress established in 2021 (and expanded in 2022).  The program...

The Need for Whistleblowers in AML Enforcement

Banking Exchange publishes article by Eric Havian and Michael Ronickher.  Click here to read the article.

BankThink: AML enforcement needs more whistleblowers

Whistleblower attorneys Eric Havian and Michael Ronickher published in the American Banker (Jan. 7, 2019).

Constantine Cannon Partner Marlene Koury Featured in Law360 on How FinCEN’s Record $80M Fine Paves the Way for FinCEN Whistleblower Awards

By the Constantine Cannon Whistleblower Team On April 21, Constantine Cannon Partner Marlene Koury shared an Expert Analysis in a Law360 article titled “Record Penalty Sets Stage For FinCEN Whistleblower Awards.” Koury analyzed the importance of Financial Crimes Enforcement Network (FinCEN)’s proposed rule to launch monetary awards under its whistleblower program, enhancing enforcement of the Bank Secrecy Act and economic sanctions. She dove into FinCEN’s recent agency action, a record $80...

Top 10 Whistleblower Awards for 2025 - False Claims Act Whistleblowers Dominate the List

By the Constantine Cannon Whistleblower Team As we reported in our post on the Department of Justice (DOJ) annual False Claims Act roundup, 2025 was a record year for False Claims Act recoveries, with DOJ bringing in $6.9 billion under the statute last year.  The majority of that amount -- more than $5.3 billion -- came from actions originated by whistleblowers under the qui tam provisions of the statute. What Type of...

CFTC Makes $1.8M Whistleblower Award -- Second Award Under Trump Administration

By the Constantine Cannon Whistleblower Lawyer Team Shortly before the holidays (on December 19), the Commodity Futures Trading Commission (CFTC) announced a $1.8 million award to two whistleblowers “whose information significantly contributed to the successful resolution of enforcement cases involving defrauded investors.”[1]  It is only the second award under the CFTC Whistleblower Program since President Trump took office, the first one (of $700,000) being awarded in May. Like the Securities...