If you work in anti-money laundering (AML) compliance, you’re likely on the front lines of detecting illicit finance—whether it’s through suspicious customer behavior, ignored red flags, or management’s failure to file required reports. But what if your institution isn’t just falling short—it’s violating the law?
Thanks to the Anti-Money Laundering Act (AMLA) Whistleblower Program, professionals like you now have a secure, potentially high-reward pathway to report these violations. And if your information leads to a successful enforcement action, you could be entitled to a monetary award of up to 30% of the total sanctions collected.
This post is a guide specifically for AML officers, compliance professionals, auditors, and risk managers who may have witnessed wrongdoing inside their financial institutions—and are ready to take the next step.
What Is the AMLA Whistleblower Program?
The AMLA Whistleblower Program, administered by FinCEN (Financial Crimes Enforcement Network), was created to encourage reporting of serious violations of the Bank Secrecy Act (BSA) and related AML and economic sanctions laws.
It covers both U.S. and foreign individuals and offers the following core features:
- Monetary awards: 10–30% of sanctions over $1 million
- Confidentiality: Identities are kept strictly confidential
- Anti-retaliation protections: Employees are protected from firing, demotion, or harassment
- Global scope: Applies even to foreign entities and actions if there’s a U.S. nexus
Who Can Report?
You don’t need to be an executive or senior insider. Many successful whistleblower cases begin with information from:
- AML analysts who flagged but saw no follow-up on SAR-worthy activity
- Compliance officers whose internal warnings were ignored
- Risk professionals who discovered systemic failures in monitoring
- Employees instructed to overlook or underreport certain transactions
- Third-party vendors or consultants with visibility into compliance operations
Even if you were part of the compliance review process, you may still be eligible for an award as long as you provide original, non-public information that leads to enforcement.
What Types of Violations Should Raise Concern?
If you’ve encountered any of the following, it may be worth a confidential legal consultation:
- Ignored or suppressed SARs
- Repeat customers involved in suspicious transactions with no enhanced due diligence
- Deliberate misclassification of high-risk accounts to avoid scrutiny
- Inadequate or “check-the-box” KYC/CDD procedures
- Failure to file required Currency Transaction Reports (CTRs)
- Management overriding system-generated alerts
- Cryptocurrency platforms or fintechs skirting BSA obligations
- Sanctions violations involving blocked persons, shell companies, or sanctioned jurisdictions
How to Safely Blow the Whistle
Reporting financial misconduct—especially when it involves your own employer—requires careful planning. Here’s how to protect yourself:
1. Contact an experienced whistleblower attorney first
Do not report directly to FinCEN or a regulator without legal advice. A lawyer can:
- Help assess whether your information qualifies
- Structure your tip to preserve your claim
- File it anonymously if necessary
- Maximize the likelihood of an award
- Protect you from retaliation
2. Do not take documents unlawfully
While internal evidence can strengthen your case, never remove or transmit documents in violation of company policy or the law. Your attorney can guide you on what’s permissible.
3. Preserve your credibility
Keep a detailed record (privately and securely) of what you witnessed, when, and how. Your memory may fade, but notes made contemporaneously can support your case.
4. Stay discreet
Avoid discussing your concerns with coworkers or managers. Confidentiality is key to preserving both your safety and your legal rights.
Why Act Now?
The AMLA Whistleblower Program is still relatively new, which means the pipeline of tips is not yet saturated. Regulators are actively seeking leads, especially in emerging areas like cryptocurrency, cross-border payments, and sanctions evasion.
If you’ve been sitting on a pattern of misconduct, now is the time to act. You could be doing the right thing—and securing a financial reward for it.
Talk to Our Firm Confidentially
Our firm represents AML professionals who are considering reporting serious compliance failures. We will:
- Evaluate your case in full confidentiality
- Help you determine if you have a valid whistleblower claim
- File your submission in a way that protects your identity and enhances your chance of an award
- Stand by you if retaliation becomes a concern
We are former government attorneys and experienced compliance counsel who understand both the legal landscape and the internal dynamics of financial institutions.
Reach out today to schedule a confidential consultation. It’s free, secure, and could be the first step toward both justice and financial recovery.