Treasury Offers Bounties for Financial Crime Tipsters!
Published Date: 4/1/2026
Proposed Rule
Summary
FinCEN is rolling out a new whistleblower program to reward and protect people who report shady financial crimes like money laundering and terrorist financing. This program affects anyone with insider info on violations of key laws and aims to keep our financial system safe. Comments on the proposed rules are open until June 1, 2026, and whistleblowers could earn cash rewards for their tips!
Analyzed Economic Effects
12 provisions identified: 6 benefits, 6 costs, 0 mixed.
Award Percentages: 10% Minimum, Up to 30%
The statute allows awards of up to 30 percent of monetary sanctions collected in certain cases. For violations added by the AML Whistleblower Improvement Act (IEEPA, TWEA, Kingpin Act), eligible whistleblowers are guaranteed a minimum award of 10 percent of monetary sanctions.
New FinCEN Whistleblower Program
FinCEN is proposing a new whistleblower program that offers cash rewards and legal protections for individuals who report possible violations of the BSA, IEEPA, TWEA, or the Kingpin Act. The program applies to natural persons (U.S. or non‑U.S.) who provide original information to Treasury, DOJ, or their employer and seeks to boost tips that help enforce those laws.
Monetary Threshold for Awards: $1,000,000
A whistleblower can receive an award only if the related judicial or administrative action results in monetary sanctions exceeding $1,000,000. If the enforcement action does not exceed $1,000,000 in monetary sanctions, it will not qualify as a "covered action" for awards.
Must Provide "Original Information" Elements
To be eligible for an award, whistleblowers must provide "original information" that meets four elements: derived from the whistleblower's independent knowledge or independent analysis; not already known to Treasury or DOJ (unless the whistleblower is the original source); not exclusively from public sources; and provided to Treasury or DOJ within the statute's date limits.
Anti-Retaliation Protections with Statutory Exclusions
Section 5323 includes anti-retaliation protections that prohibit employers (with certain statutory exclusions) from retaliating against whistleblowers who provide information, testify, or cooperate. The protections do not apply with respect to any employer that is subject to 12 U.S.C. 1831j or 12 U.S.C. 1790b or 1790c.
Awards Funded by Revolving Fund for Timely Payments
The AML Whistleblower Improvement Act created a revolving fund that receives penalty deposits so eligible whistleblowers can receive awards without the need for further appropriations. This is intended to allow timely payments of awards.
What Counts: Monetary Sanctions vs. Non‑Monetary Items
For calculating awards, "monetary sanctions" include monies like penalties, fines, settlements, disgorgement, and interest. They do not include blocked property, forfeiture, restitution, or victim compensation payments (including amounts deposited to the U.S. Victims of State Sponsored Terrorism Fund).
FinCEN Can Aggregate Multiple Actions
FinCEN may treat two or more judicial or administrative actions that arise from substantially the same facts and are successfully enforced at substantially the same time as a single "covered action," allowing aggregation of monetary sanctions to meet the $1,000,000 threshold.
Eligibility Dates for Original Tips
To qualify as "original information" for awards, tips about BSA violations must be first provided after January 1, 2021. Tips about IEEPA, TWEA, the Kingpin Act, or conspiracies to violate those statutes must be first provided after December 29, 2022.
120-Day Waiting Period for Some Submissions
Certain whistleblowers who obtained information because they meet criteria specified in the proposed rule must wait at least 120 calendar days from the date they obtained the information before providing it to FinCEN to be eligible for an award. The waiting period is intended to give entities time to use internal compliance programs.
Submission Process: Form TCR and Anonymity Allowed
Whistleblowers must initially submit original information to FinCEN using FinCEN's "Tip, Complaint, or Referral" form (Form TCR) through a secure online portal, although FinCEN may authorize other methods. Individuals may submit anonymously and may use an attorney; each whistleblower must submit their own Form TCR and must certify the submission is true and complete.
Only Natural Persons Can Be Whistleblowers
Under the proposed rule, a "whistleblower" is any individual or two or more individuals acting jointly; legal entities like corporations, LLCs, and trusts cannot be whistleblowers and cannot receive awards under the program.
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