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

Posted February 25, 2026

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 rewards whistleblowers for reporting money laundering violations under the Bank Secrecy Act (BSA) and sanctions violations under the various statutes that prevent doing business with sanctioned entities. Whistleblowers can receive up to 30% of the Government’s recovery from any resulting AML or sanctions enforcement action.

What Is the Significance of FinCEN’s Recent Launch of a Dedicated AML/Sanctions Whistleblower Website?

FinCEN’s creation of a dedicated whistleblower webpage is notable because there has been little activity with the program since its inception. Indeed, there have been no reported rewards paid out under the program to date. Nor has FinCEN done much to promote the program. Many are wondering if things are about to change with this announcement and the Trump Administration’s enforcement focus on fraud and misconduct by foreign actors that negatively impacts U.S. markets.

In the Treasury Department’s press release announcing the newly launched whistleblower website, Treasury Secretary Scott Bessent underscored the Government’s renewed focus on AML/Sanctions-type violations and its hope that whistleblowers will play a key enforcement role:

“President Trump has been clear that Americans have a right to know that their tax dollars are not being diverted to fund acts of global terror or to fund luxury cars for fraudsters. At Treasury, we follow the money. We did it with the mafia, we have done it with the cartels, and we’re doing it with the Somali fraudsters. We are going to offer whistleblower payments to anyone who wants to tell us the who, what, when, where, and how this fraud and money laundering has occurred.”

This language also is prominently displayed on the new whistleblower website as is the banner headline “Urging Whistleblowers to Come Forward.”[2] Immediately under this whistleblower exhortation is a video clip from a Fox News interview of the Secretary by Laura Ingraham, where Secretary Bessent again presses whistleblowers to come forward with the promise of potential rewards and the recognition that the help of whistleblowers “will give us a great leap forward” on going after this kind of misconduct.

The website also provides detailed information about the program, including relevant information relating to: (i) the underlying statutes the program covers, (ii) the legislation underlying the program, (iii) the anti-retaliation protections for whistleblowers reporting under the program, (iv) program updates, and (v) how to submit a tip under the program.

Is FinCEN Poised to Make Its First Awards Under the AML/Sanctions Whistleblower Program?

In a further nod to FinCEN’s efforts to push this program to the next level, the website notes that “FinCEN plans to publish a regulation to fully implement” the program and once it does “will begin processing and paying awards.”

Constantine Cannon whistleblower partner Marlene Koury — who has made numerous submissions under the AML/Sanctions Whistleblower Program — is heartened by what she sees as the Government’s renewed commitment to the program:

“My experience with the agency has been very positive. FinCEN has given our matters serious attention and treated our whistleblower-clients with a lot of respect and appreciation. We are excited by this next phase of the program where the agency moves forward with its enforcement efforts and gives due credit to the whistleblowers who helped them get there.”

Koury expects that we will see the first awards coming down the pike soon, with a steady stream of awards to follow. “That is what happened with the SEC Whistleblower Program, which launched about a decade before the AML/Sanctions Program,” Koury said. “There were a few years of build up and then the awards started flowing, with more than $2 billion in SEC whistleblower awards that followed.”

What Conduct is Covered Under FinCEN’s AML/Sanctions Whistleblower Program?

The AML/Sanctions Whistleblower Program generally covers anti-money laundering violations under the BSA and sanctions violations under the International Emergency Economic Powers Act, the Trading With the Enemy Act, and the Foreign Narcotics Kingpin Designation Act. While FinCEN runs the whistleblower program and generally enforces the BSA. The Treasury Department’s Office of Foreign Assets Control (OFAC) enforces the economic trade and sanctions statutes.

In terms of what type of AML and sanctions misconduct to look out for, FinCEN put out a Bulletin which identifies some of the more common AML and sanctions violations the FinCEN whistleblower program covers:[3]

- A financial institution failing to perform sufficient due diligence on a customer that is a recently established company or non-profit enrolled in a Government benefit program suddenly receiving a significant amount in Federal payments soon after starting its operations.

- A financial institution lacking sufficient controls to detect potential “smurfing” issues where large deposits at convertible virtual currency kiosks are separated into multiple, lower-value transactions across multiple locations to avoid detection.

- A financial institution lacking sufficient controls to detect virtual currency “pig butchering” investment scams.

- A financial institution failing to comply with a Geographic Targeting Order designed to combat money laundering in particular industries or regions especially prone to fraud.

- A company submitting falsified trade-related documentation to conceal a nexus to sanctionable activity, a sanctioned jurisdiction, or a Specially Designated National (SDN) involvement in the transaction.

- A U.S.-based person sending multiple wire transfers to Mexican financial institutions with memos such as “taxes” or “fees” for a timeshare (suggesting SDN involvement).

Constantine Cannon Has Substantial Experience Representing Whistleblowers Under FinCEN’s AML/Sanctions Whistleblower Program

If you have information relating to these potential violations or other potential AML and sanctions violations, please do not hesitate to contact us. Constantine Cannon has substantial experience representing whistleblowers under the FinCEN AML/Sanctions Whistleblower Program. We will connect you with an experienced member of our whistleblower team for a free and confidential consultation.