FinCEN AML and sanctions whistleblower program

What FinCEN says it covers

FinCEN says the program offers incentives and protections for information about violations, or conspiracies to commit violations, of the Bank Secrecy Act, the International Emergency Economic Powers Act, the Trading With the Enemy Act, or the Foreign Narcotics Kingpin Designation Act, and their regulations. ¹ Source 1

A person may be eligible if the information leads to a successful enforcement action by Treasury or the Justice Department that results in monetary penalties exceeding $1,000,000, and the requirements of 31 U.S.C. § 5323 and its implementing regulation are met. FinCEN says it shares information with OFAC and with named Justice Department sections that enforce those laws. ¹ Source 1

Award range, and the open rulemaking

The 2023 edition of the U.S. Code, as posted on GovInfo, states that in a covered action or related action the Secretary shall pay an aggregate award of not less than 10 percent and not more than 30 percent of what has been collected of the monetary sanctions. A covered action is one that results in monetary sanctions exceeding $1,000,000. The award is paid under regulations prescribed by the Secretary, in consultation with the Attorney General. ² Source 2

The same section defines monetary sanctions as monies, including penalties, disgorgement, and interest, ordered to be paid. It excludes forfeiture, restitution, and any victim compensation payment. An award percentage is a percentage of the sanctions that fit that definition, not of every dollar associated with a case. ² Source 2

FinCEN’s program page says it plans to publish a regulation to implement the statute as amended by the Anti-Money Laundering Act of 2020 and the Anti-Money Laundering Whistleblower Improvement Act of 2022. It says that once the regulation is finalized, FinCEN will begin processing and paying awards. It says an NPRM on whistleblower incentives and protections was published on April 1, 2026, with comments due within 60 days of Federal Register publication. This page does not treat awards as currently being paid. ¹ Source 1

How information reaches FinCEN

The statute says a whistleblower provides information to the employer, the Secretary, or the Attorney General, as applicable, and that the Secretary may require a form by rule. FinCEN’s public page describes the program and the pending rule. It does not, in the text reviewed for this edition, name a form number. ¹ Source 1 ² Source 2

The report button on this page goes to America.gov/fraud, which lists FinCEN among offices a report may be routed toward. That routing sentence is the portal’s description, not a determination that a given report will be treated as a FinCEN award claim. ³ Source 3

Anonymity and confidentiality

The statute says a whistleblower who anonymously makes an award claim shall be represented by counsel if the information was submitted anonymously. Before payment, the whistleblower shall disclose their identity and provide other information the Secretary may require, directly or through counsel. ² Source 2

The statute also says the Secretary or the Attorney General, and officers and employees of Treasury or Justice, shall not disclose information that could reasonably be expected to reveal a whistleblower’s identity, except as the section provides, including disclosure required to a defendant or respondent in a public proceeding. FinCEN’s page says it is committed to protecting confidentiality in accordance with section 5323. ¹ Source 1 ² Source 2

Deadlines

FinCEN’s program page, as reviewed on October 21, 2026, does not state a number of days in which to submit a tip. The statute says a determination, including whether, to whom, or in what amount to make awards, is in the Secretary’s discretion, and that certain determinations may be appealed to a court of appeals not more than 30 days after the determination is issued. The amount of an award made within the statutory band is excepted from that appeal right. ¹ Source 1 ² Source 2