To decide how to report money laundering fraud, start with our whistleblower experts and the transactions, warnings or control decisions you know from inside the business. An analyst may know why an alert never reached an investigator. A relationship manager may know what the bank told a correspondent after an internal warning. An exchange employee may know why a supposedly blocked customer kept trading. We connect that knowledge to the evidence and the whistleblower program suited to your case.
Useful evidence connects the movement of money to the people and decisions that allowed it. We begin with the institution involved, your work there, the conduct you observed and where the supporting records sit.
You may know which team maintains the payment messages or who approved a monitoring exception without holding those files yourself. That knowledge is part of what we assess with you.
The legal entity, department and period of your work help place your account. Customer or account identifiers, transaction dates, currencies and amounts connect it to activity investigators can examine. We work through what you saw directly, what others told you and which amounts are estimates. A warning also has a history: who received it, who could act and what happened afterward.
The International Labour Office’s 2019 working paper, Law and practice on protecting whistle-blowers in the public and financial services sectors, explains why employees can bring something outsiders lack: access to the institution’s operational practices and finances. That is the contribution we look for here. An insider can explain the decision behind the transaction history.
The records that matter connect the alert, the review, the warning and the decision. We assess those connections with you, including where investigators could obtain additional evidence.
Customer onboarding files describe the business the institution expected to see. Transaction records show the activity that followed. Monitoring rules, testing results, staffing requests and exception approvals can explain why the activity received little scrutiny. Compliance, operations, audit and technology staff may each know a different part of that history.
Suspicious activity report confidentiality and access rights belong in that conversation with us and money laundering whistleblower counsel. The starting point is your account of the underlying transactions and decisions.
In the statement of facts attached to its 2012 deferred prosecution agreement, HSBC Bank USA admitted that senior business executives froze anti-money laundering staffing to cut costs and increase return on equity. Departing employees went unreplaced, jobs were combined and new positions went uncreated. The bank already had fewer anti-money laundering employees than its own plans required.
The bank knew its controls were deficient. It cut the resources for those controls to improve profits. A staffing request and the answer to it can show who made that choice.
TD Bank’s 2024 guilty plea and stipulated facts show another version of that problem. Budget constraints left domestic ACH transactions and most checks outside monitoring. For an employee who knows the systems, the useful detail is the excluded payment channel, the request to cover it and the response from the people controlling the budget.
Danske Bank admitted in its 2022 guilty plea that it misled U.S. banks to preserve access to dollar payments for its Estonian branch. A whistleblower’s warnings and internal audits exposed problems inside the bank while it continued misrepresenting customer risk and controls to its U.S. correspondents.
The internal warning and the later answer to a correspondent belong beside each other. The first shows what reached management. The second shows what the bank told the institution it needed to keep the money moving.
Payment messages can reveal a similar split. Standard Chartered’s 2012 New York consent order described the removal or omission of Iranian identifiers from payments. Original messages, altered messages and the instructions behind the changes connect the payment to the decision about what another bank would see.
Bank of America admitted failures in its 2026 FinCEN consent order involving Event Processor, the system that grouped customer alerts and scored them for investigation. Older alerts stopped contributing to the score. Testing showed suspicious activity below the investigation threshold, yet the bank retained that threshold until it later changed the system.
That puts the model’s settings, testing results and approval history at the center of the story. The alert existed. The question was whether the bank’s chosen rules would ever bring it to an investigator.
Under its 2012 deferred prosecution agreement, MoneyGram admitted failures that included management rejecting fraud staff’s recommendations to terminate agents. Information also failed to flow adequately between fraud and anti-money laundering teams. Scam victims’ money kept moving through agents the fraud staff wanted removed.
Agent identifiers, customer complaints and management responses can show what happened to the business after staff raised the concern.
In its 2024 non-prosecution agreement, Wynn Las Vegas admitted using unregistered money transmitters. The admitted conduct included routing patrons’ funds through nominee companies into a Wynn-controlled account and then the casino cage, and using proxy gamblers to conceal the actual patron. Cage records, patron accounts and the intermediary’s transfers can connect the person gambling to the person supplying the money.
Our whistleblower experts assess the exchange’s internal customer and control history alongside the transfers you can explain. A public transaction hash shows a transfer. The internal ledger can connect it to the customer credited by the exchange, while account permissions and wallet controls help explain who could move the value.
If you want to report crypto exchange money laundering with internal ledger and wallet evidence, we examine those records together with customer identification, screening, exception and escalation histories. The blockchain and the exchange’s books reveal different parts of the same activity.
Binance’s 2023 guilty plea gives that distinction a concrete form. The company admitted helping U.S. VIP customers maintain access through accounts for offshore entities. Its internal instructions told staff how to handle customers whose U.S. identification had already exposed their location:
We cannot tell users in any way we are changing their KYC, this is not compliant. We are basically correcting previously inaccurate records in light of new evidence.
Binance internal instructions, quoted in the statement of facts attached to its guilty plea, 2023.
The document presented a way to keep the customer trading as a correction to the records. Customer-support scripts, earlier identification and account changes could show that choice in a way a public wallet trace could not.
Start with our whistleblower experts to assess your account and the reporting path it supports. The Financial Crimes Enforcement Network’s whistleblower program covers Bank Secrecy Act violations and specified U.S. sanctions violations, including conspiracies to violate those laws. We work with money laundering whistleblower lawyers on the evidence and the agency submission.
The legal entity and its business matter. A bank’s correspondent activity, a money transmitter’s agents and an exchange’s customer access raise different questions. Securities or commodities conduct may also bring the Securities and Exchange Commission or Commodity Futures Trading Commission whistleblower program into the assessment. Tax violations may bring the Internal Revenue Service whistleblower program into the assessment. The Justice Department has a separate corporate whistleblower program. We assess those possibilities with you as part of choosing the route.
FinCEN’s statutory award range is 10% to 30% of qualifying collected monetary sanctions for eligible whistleblowers collectively. Its program page says the information must lead to successful enforcement with monetary penalties exceeding $1 million.
FinCEN also welcomes non-U.S. whistleblowers. If you work outside the United States, we can assess how your knowledge of correspondent payments or exchange accounts fits the U.S. program.
A knowingly false claim for government payment, or knowingly keeping money owed to the government, can raise a separate False Claims Act question. We assess that connection where your account includes it.
A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers.
Earlier internal reports, agency submissions and later developments help establish what was communicated and when. We review that history with you, including any receipts, reference numbers and follow-up exchanges.
A later transaction, a changed control or a newly discovered management response may add to the account.
If you know which warning was ignored, which payment channel escaped monitoring or why a blocked customer kept trading, speak to one of our Whistleblower Experts about reporting money laundering fraud. We build the case around the transactions and decisions you know, bring in money laundering whistleblower lawyers with the specific expertise your case needs, and stand with you through the pursuit of a recovery and your share.