The Anti-Money Laundering Act (AMLA) of 2020 created a whistleblower reward program for individuals who report violations of the Bank Secrecy Act, the primary anti-money laundering law in the United States. The program, administered by the Financial Crimes Enforcement Network (FinCEN), has been in effect since January 1, 2021. The AMLA specified that the whistleblower program would go into effect immediately, without the need for implementing regulations. The program is modeled on the extremely successful SEC whistleblower program for securities law violations, recognizing a similar need for help from brave individuals with information about money laundering.

It has been nearly five years since the FinCEN whistleblower program was born. Senator Chuck Grassley, a strong advocate for whistleblower programs as a fraud-fighting tool, expressed concern about delays in implementation of the whistleblower program in an open letter to FinCEN on February 2, 2024. There are still no regulations, nor is there a dedicated website for the whistleblower office or a portal for submitting whistleblower tips, as there is for the SEC program. Current and prospective whistleblowers with insight into money laundering operations eagerly await regulations to clarify how the whistleblower program will function.

There is limited published information about how many tips the FinCEN whistleblower office has received. The public is left to piece together bits of information like a speech from FinCEN director Andrea Gacki at an AML conference on May 6, 2024: “We have received over 270 unique tips since the program’s inception, and many of the tips received have been highly relevant to many of Treasury’s top priorities.” In the same speech, Director Gacki also acknowledged that the program “holds tremendous potential as an enforcement force-multiplier.”

The U.S. Sentencing Commission reports that money laundering offenses increased by 45% between fiscal year 2020 and fiscal year 2024, with 1,095 cases involving money laundering offenses in 2024. FinCEN has a broad anti-money laundering mandate. In addition to traditional banks, FinCEN regulates, and the Bank Secrecy Act covers, money services businesses (MSBs) including currency dealers or exchangers; check cashers; issuers of traveler’s checks, money orders, or stored value; sellers or redeemers of traveler’s checks, money orders, or stored value; money transmitters; and the U.S. Postal Service. As of August 8, 2025, there are 27,329 MSBs registered in FinCEN’s online database. Money laundering itself is a huge category that can involve the proceeds of any sort of illegal activity, from healthcare fraud to human trafficking to crypto romance scams. FinCEN has a mandate to combat money laundering across a range of typologies, which makes the need for help from whistleblowers with insight into emerging schemes and varied industries more acute.

Within the broad scope of FinCEN’s anti-money laundering oversight, the government has identified some enforcement priorities. The Trump administration has signaled a shift in enforcement emphasis toward combatting transnational criminal organizations and cartels, especially those involved in illicit drug sales within the United States, and threats to U.S. national security.

FinCEN’s most recent National Money Laundering Risk Assessment, published in February 2024, demonstrates significant anti-money laundering enforcement opportunity within these priority areas. The Assessment highlights drug trafficking organizations and professional money laundering networks, including those based in China and Russia, as continuing major threats. An April 2025 FinCEN Financial Trend Analysis reviewing 2024 data on “Fentanyl-Related Illicit Finance” revealed that 1,246 Bank Secrecy Act reports in 2024 identified suspect fentanyl-related activity, with $1.4 billion in funds involved in these suspicious transactions.

The staggering scope and scale of money laundering show that even within smaller focus areas under the anti-money laundering umbrella, FinCEN has plenty of work to do. The agency can learn from the success of other whistleblower tip programs and do even more to embrace and reward whistleblowers who take part in the fight against money laundering.

This piece was written by Liz Soltan of Whistleblower Partners.