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.