On February 13, 2026, the U.S. Department of the Treasury (Treasury)'s Financial Crimes Enforcement Network (FinCEN) launched a webpage to accept whistleblower tips on money laundering, sanctions violations, and fraud (the Whistleblower Webpage). The Whistleblower Webpage, which has a user-friendly reporting feature and information regarding the possible monetary awards for providing information that leads to a successful enforcement action by Treasury or the U.S. Department of Justice (DOJ), is likely to increase the number of tips reported to FinCEN.
We provide below a brief background of the current whistleblowing regime and considerations for financial institutions and other companies with Bank Secrecy Act (BSA) requirements or potential exposure to sanctioned entities, regions, or related activity.
Background
In January 2021, Congress enacted the Anti-Money Laundering Act of 2020 (AMLA), which significantly revised the BSA's existing whistleblower provisions, creating a new regime modeled on the highly successful whistleblower program of the U.S. Securities and Exchange Commission. AMLA increased the amount of potential awards for individuals whose reports lead to successful BSA/AML-related enforcement actions. Whistleblowers who voluntarily provide original information to their employer, Treasury, or DOJ could recover a maximum award of 30% of monetary sanctions collected in excess of $1 million, a substantial increase from the prior maximum of $150,000. In December...
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