FinCEN Whistleblower Program: Reporting Now While Award Rules Remain Proposed

The FinCEN Whistleblower Program accepts information about Bank Secrecy Act and covered sanctions violations now, while award processing and payment await final regulations. If you work inside a bank, money transmitter or crypto exchange, you may know how customer checks failed, why suspicious activity went unreported or who approved exceptions. That knowledge can connect the movement of money to the decisions inside the business.

Does FinCEN Have a Whistleblower Program?

Yes. FinCEN, the Financial Crimes Enforcement Network, administers Treasury’s whistleblower program for Bank Secrecy Act violations and specified sanctions violations. The program can reward individuals whose voluntary, original information leads to successful enforcement by Treasury or the Department of Justice.

Its coverage includes the International Emergency Economic Powers Act, the Trading With the Enemy Act and the Foreign Narcotics Kingpin Designation Act. FinCEN shares information with the Treasury and Justice offices that enforce these laws, including the Office of Foreign Assets Control.

The proposed rule also describes coverage reaching Treasury’s Outbound Investment Security Program and the Justice Department’s Data Security Program. These concern restricted investments in national-security technologies and access to sensitive personal and government data by countries of concern. Employees at investment and technology businesses may therefore hold relevant information too.

For an insider, the useful distinction is the conduct the business enabled. Bank Secrecy Act violations can concern an ineffective anti-money laundering program, missed suspicious activity reports, or failures of required recordkeeping and registration. Those questions can reach the same customers, payments and internal controls.

The overlap extends to digital assets. A crypto exchange’s customer records, internal ledger and screening decisions can supply information that a public blockchain transaction does not show. Someone inside the exchange may know whose account received the funds and what the business knew about that customer.

Capital One shows how failures in a particular line of business can become a major civil enforcement action. FinCEN’s civil assessment imposed a $390 million penalty over anti-money laundering and reporting failures involving check-cashing customers. The findings concerned the controls around those customers, suspicious activity reports and currency transaction reports.

What Is the AML Whistleblower Law?

The Anti-Money Laundering Act of 2020 established the modern framework when Congress enacted it on January 1, 2021. It expanded the earlier reward program, but awards still depended on appropriated funding and the law provided no minimum award percentage.

The Anti-Money Laundering Whistleblower Improvement Act changed that framework on December 29, 2022. It added a minimum award, created the Financial Integrity Fund to pay awards and expanded coverage to specified sanctions violations and conspiracies.

The old $150,000 informant-reward cap belongs to the earlier program.

What Is the Reward of a Whistleblower in Money Laundering?

FinCEN whistleblower awards collectively range from 10% to 30% of qualifying monetary sanctions collected in covered enforcement actions and qualifying related actions. The covered Treasury or Justice action must result in monetary sanctions exceeding $1 million. The range applies to the total shared among qualifying whistleblowers in the same action.

We assess how your information connects to covered enforcement and the award opportunity, with AML and sanctions whistleblower lawyers who know the program.

Who Can Be a Whistleblower in a Bank?

Bank employees can qualify, including people who learn and report information as part of their jobs. Compliance officers, investigators, auditors and operations staff may hold different pieces of the same account: what the controls required, what the transactions showed and how management responded.

You do not have to work at a bank. Information from a customer, vendor or contractor can also matter, and the law recognizes independent analysis as well as knowledge gained through work.

The law also permits participation by individuals outside the United States. It has no citizenship or residence requirement. The connection between the information and covered enforcement is what matters to this program.

What you know, or what you worked out yourself, can count toward original information. It must lead to successful covered enforcement. An employee’s explanation of how a customer exception was approved, or how an internal ledger connects transfers to an account, can give investigators a specific question to pursue.

We assess what your knowledge adds and how it connects to the conduct.

FinCEN Whistleblower Award Proposed Rules: Can I Report Now?

Yes. FinCEN accepts whistleblower information while its award rules remain proposed. We work through how and when your information goes in with you. The agency’s April 1, 2026 notice proposes procedures for submissions, award applications and decisions.

The proposal includes timing rules for information obtained through compliance and audit work, and for award claims. How those provisions apply to your role, earlier information or an internal report is part of the work we handle with you.

What Proof Do You Need as a Whistleblower?

Useful evidence connects the people, transactions, dates and control decisions to the alleged violation. Your account of the conduct supplies the connections between those records.

A bank’s customer due diligence brings together its understanding of the customer, the risk profile and ongoing monitoring. The onboarding employee may know what the customer said the account was for. The investigator may know what the transactions actually showed. The manager may know why a warning or staffing request went unanswered. We work through those different views with you to identify the decisions that explain the failure.

For digital-asset businesses, the account history can be as important as the public transfer. Wallet addresses, the exchange ledger and the customer’s identity connect different parts of the movement of funds. Your knowledge of how those systems fit together can make the activity understandable to someone outside the business.

Evidence handling, SAR confidentiality, anonymity and retaliation are matters to discuss with our whistleblower experts and the AML whistleblower lawyers we bring into your case.

Why an Insider’s Explanation Matters

A financial institution can produce a great deal of reporting while the people responsible for compliance struggle to get their concerns heard inside the business. The public needs those controls to combat money laundering and terrorist financing, not simply to generate reports.

Anti-Money Laundering: Opportunities for Improvement, published by the Wharton Initiative on Financial Policy and Regulation in 2024, puts the gap between compliance work and results plainly:

The paper explains that rising suspicious activity report volumes can reflect better detection, expanded obligations or defensive reporting. The available data make those explanations difficult to separate. It also discusses research suggesting that compliance officials often see themselves as aligned with law enforcement while others inside their firms treat their work as an expense to minimize.

That tension gives an insider’s account its practical value. A transaction record shows the payment. The person who worked on the account may be able to explain the warning, the decision and why the business kept processing it. We look for those connections when assessing what your information can establish.

FinCEN Whistleblower Fund Balance Versus Awards Actually Paid

The FinCEN whistleblower fund balance shows substantial money set aside while award processing and payment await final rules. Treasury’s fiscal-year-end account statement recorded $959,031,611 in the Financial Integrity Fund on September 30, 2025, held in Treasury securities.

The statute uses a $300 million threshold to govern ordinary deposits into the fund. That threshold is not the fund’s balance or an absolute ceiling on it. The fund is reserved for awards.

The money was there at fiscal year-end. The rules for paying whistleblowers remain proposed.

How FinCEN Fits Beside Other Whistleblower Programs

FinCEN’s program addresses covered Bank Secrecy Act and sanctions violations. SEC and CFTC awards concern their respective securities and commodities enforcement. The Justice Department’s corporate whistleblower pilot pays from qualifying money forfeited to the government.

A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers. We assess which program fits the conduct and bring in whistleblower lawyers with the relevant AML, sanctions, securities or commodities experience.

When You Know Why the Controls Failed

If you know how a bank, payment business or crypto exchange let transactions through despite the information inside the business, speak with our whistleblower experts about what happened. We connect your knowledge of the accounts, warnings and decisions to a whistleblower case, and bring in AML and sanctions whistleblower lawyers who understand the business. We stay beside you through the case, from assessing the information to pursuing the award.