If you have information regarding money laundering or sanctions violations, you may be eligible for a monetary award of between 10% and 30% of the recovery under FinCEN’s Anti-Money Laundering-Sanctions Whistleblower Program.

Working pro bono, IWA advocated for the establishment of the AML Whistleblower Program. Now, they are working to ensure that the Treasury and Department and FinCEN pass effective regulations which work for international whistleblowers.

The AML whistleblower attorneys at International Whistleblower Advocates (IWA) can guide you through the entire whistleblowing process – from anonymously submitting a tip to apply for rewards and protecting yourself against retaliation if it occurs.

Big Cases. Big Wins.

Bradley Birkenfeld

Striking a Blow Against Bank Secrecy in Switzerland

International banker and wealth manager at UBS bank in Switzerland who in 2007, blew the whistle tax evasion scheme involving 4,450 U.S. taxpayers. UBS was required to pay a fine of $780 million, and Birkenfeld received an award of $104 million from the IRS whistleblower awards – the largest up until 2020. Birkenfeld’s award remains historically significant as it demonstrated the power of the modernized IRS whistleblower program and helped end Swiss banking secrecy for American tax evaders.

Howard Wilkinson

The Whistleblower Who Exposed a $230 Billion Money Laundering Scandal

Former Danske Bank manager who exposed a $230 billion Russian money laundering scheme that moved rubles to dollars from Russia to the United States with the help of Danske Bank Estonia. This case is still ongoing and considered the largest money laundering scheme in history. So far, Howard’s whistleblowing has recovered over $2 billion for victims of the fraud. In 2020, the Association of Certified Fraud Examiners, one of the world’s largest and most respected organizations of auditors, compliance officials, and fraud examiners, gave Mr. Wilkinson its highest honor: The Cliff Robertson Sentinel Award “For Choosing Truth Over Self.”

This is a snapshot of our successful history of winning that spans over 37 years as whistleblower attorneys, but also as key policy drafters and advocates who work closely and consistently with U.S. legislators to ensure whistleblowers are awarded and protected for their tips.

We’ve represented U.S. and foreign bank employees, former employees, customers, clients and other contractors who have access to sensitive information and decided to do what’s right by reporting their concerns to the U.S. government and regulatory authorities.

Compliance personnel are often ideal whistleblowers because their jobs provide them significant insight into legal violations.

If you have information regarding violations of AML laws or sanctions violations, or violations of the Bank Secrecy Act (BSA) and would like to anonymously report your concerns and seek a reward, contact our AML whistleblower lawyers today for a free and confidential consultation to understand what your options are.

Our Anti-Money Laundering Practice

Our team is comprised of former top U.S. officials from the SEC and leading whistleblower attorneys who have fought tooth and nail on precedent-setting whistleblower cases and on Capitol Hill to ensure transnational laws and programs like the FinCEN’s Anti-Money Laundering-Sanctions Whistleblower Program are successful — and not just for whistleblowers, but for the U.S. financial system and national security.

Our Attorneys

• 

  David K. Colapinto

  Supervising Attorney

  Leading whistleblower attorney and expert across all practice areas.

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• 

  Stephen M. Kohn

  Chief Supervising Attorney

  Stephen M. Kohn is one of the nation’s leading whistleblower attorneys.

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• 

  Allison H. Lee

  Securities, Commodities and FCPA Expert

  Former SEC Commissioner and Chair

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• 

  Todd Yoder

  Supervising Attorney

  Represents whistleblowers in both federal litigation and whistleblower reward programs.

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Our Legislative Impact

Through sustained advocacy from 2018 to 2021, IWA and NGOs helped secure passage of the Anti-Money Laundering Improvement Act, which protects and rewards whistleblowers who expose sanctions violations, oligarch wealth, and illicit financial schemes — enabling the Treasury to track billions in laundered funds and seize criminal assets.

Whether you’ve witnessed a single violation or uncovered a systemic compliance failure, International Whistleblower Advocates is prepared to guide you through the FinCEN whistleblower process from initial consultation through award collection.

Our team understands the complexity of BSA and sanctions enforcement, the agencies involved, and what it takes to present your information effectively.

FinCEN Whistleblower Program: Our Areas of Expertise

International Whistleblower Advocates represents clients in cases involving Bank Secrecy Act violations and sanctions laws, including the International Emergency Economic Powers Act, Trading with the Enemy Act, and Foreign Narcotics Kingpin Designation Act. Our practice aligns with FinCEN’s enforcement priorities across these key areas:

Reporting Failures

Financial institutions are required to file Currency Transaction Reports (CTRs) and Suspicious Activity Reports (SARs) when transactions suggest potential money laundering. IWA represents whistleblowers who come forward when their institutions fail to meet these critical obligations.

Structured Transactions

Breaking large transactions into smaller amounts to evade detection is a serious BSA violation. We represent individuals who have witnessed or been directed to participate in structuring schemes, as well as those reporting such activity by third parties.

Recordkeeping Violations

The BSA mandates that financial institutions maintain comprehensive records of customer transactions and identities. IWA advocates for whistleblowers who expose institutional failures to comply with these documentation requirements.

Know Your Customer (KYC) Deficiencies

Customer due diligence is foundational to anti-money laundering compliance. We represent whistleblowers who report when their employers fail to verify customer identities or maintain current, accurate KYC data.

Money Laundering Schemes

IWA represents whistleblowers exposing money laundering at every level—from individual actors to institutional schemes involving structuring, commodities, shell companies, and asset acquisitions designed to obscure illicit funds.

Sanctions Violations

The Treasury Department’s Office of Foreign Assets Control (OFAC) enforces sanctions programs targeting Russia, Iran, Syria, Chinese military companies, terrorist organizations, narcotics traffickers, and others.

Terrorism Financing

IWA also represents whistleblowers with information about activity that may fund terrorism or threaten national security — a critical component of FinCEN’s mission to protect the U.S. financial system.

Cryptocurrency & Virtual Currency Violations

The rapid growth of digital assets has created new opportunities for financial crime. IWA represents whistleblowers who expose cryptocurrency exchanges, kiosk operators, and peer-to-peer platforms that fail to register as money services businesses, lack adequate AML programs, or enable transactions with sanctioned jurisdictions.

Real Estate Money Laundering

All-cash real estate purchases through shell companies and trusts have long been a favored method for laundering illicit funds. IWA represents whistleblowers in the real estate industry — including title agents, escrow companies, and settlement professionals — who report failures to comply with FinCEN’s reporting requirements for residential real estate transfers.

Human Trafficking & Exploitation

Financial institutions play a critical role in detecting the money flows that enable human trafficking and child exploitation. IWA represents whistleblowers who report their institution’s failure to identify or report suspicious transactions linked to these crimes, helping law enforcement protect vulnerable victims.

Correspondent Banking Violations

U.S. banks that maintain accounts for foreign financial institutions must conduct rigorous due diligence. IWA represents whistleblowers who expose failures to properly vet foreign correspondent relationships or detect suspicious transactions flowing through these accounts.

Beneficial Ownership Violations

The Corporate Transparency Act requires disclosure of the true owners behind legal entities. IWA represents whistleblowers who report failures to collect, verify, or maintain accurate beneficial ownership information — a critical tool for uncovering shell company schemes.

Financial crimes thrive in secrecy, and whistleblowers are often the only ones positioned to expose them. If you have knowledge of any of these violations, we urge you to contact IWA for a confidential consultation to discuss your options and eligibility.

Determining Eligibility Under FinCEN

Given the transnational nature of money laundering, the FinCEN’s Anti-Money Laundering-Sanctions Whistleblower Program allows U.S. and foreign citizens to anonymously report AML or sanctions violations. This means that anyone who possesses information about a money laundering scheme can become eligible for award and protection.

Other eligibility requirements include:

• Original Information: You must provide the government with original information about a possible violation of the BSA or the implementation regulations. This means the information must be new to the government and not already known to them.
• Voluntary Disclosure: It’s important that you provide the information to the government voluntarily. You cannot be coerced or pressured into coming forward.
• Successful Enforcement Action: The information you provide must lead to a successful enforcement action against a person or entity that has violated the BSA or the implemented regulations.
• Timely Disclosure: You must submit the information to the government before the agency has already reported the violation.

If you meet these general requirements, then you have the right to file an anonymous tip. A whistleblower can submit a tip anonymously while remaining eligible for a whistleblower award, but only if he or she is represented by counsel.

FinCEN Whistleblower Award

If monetary sanctions exceed $1 million, whistleblowers must be awarded between 10% and 30% of the sanctions collected. They are also protected against retaliation, which is prohibited when a whistleblower reports to a federal entity such as FinCEN.

Furthermore, if you become eligible to receive a FinCEN whistleblower award, the amount of your award will be determined, in part, by the amount of assistance you provide. For instance, how involved you were in an investigation.

The program allows for reporting violations that occurred up to six years before the whistleblower has reported.

Why Seek Our Expert AML Legal Assistance

An experienced whistleblower attorney like IWA can help you navigate the complex legal landscape, protect your identity, and uphold your rights. And remember, if you choose to file anonymously, you must have an attorney.

We can help prepare the submission to, and interact with, the Treasury and other regulators, which can increase the odds that the government pursue the case, and increase the chances of receiving the maximum award possible.

Additionally, if you disagree with FinCEN’s award determination — whether the bureau denies your award request or disagrees with its calculation of your award amount — you will have the option of filing an appeal, which an AML attorney can assist you with.

Important Considerations

It’s important to note that there are other award programs that whistleblowers might consider, depending on the type of financial entity. For instance, if the entity in question is overseen by the SEC, whistleblowers can explore the SEC Whistleblower Reward Program.

If the entity falls under the CFTC’s jurisdiction, the CFTC Whistleblower Reward Program is available. It’s worth noting that whistleblowers have the option to provide information to multiple programs simultaneously.

Contact Us Today!

Our attorneys work on a contingency basis, which means we don’t get paid unless you obtain an award resulting from our legal representation. Get in touch now to learn more about your options and to begin the process of submitting a tip.

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