How Do I Apply for an Award After an Enforcement Action Ends?

If you gave U.S. authorities information about suspected money laundering or another Bank Secrecy Act violation, an enforcement action may eventually lead to a financial award. But an action ending does not automatically mean you qualify—or that an award will be paid. You generally must have provided useful, original information through the proper channel, meet the program’s requirements, and submit a separate award claim on time.

This guide explains the U.S. Anti-Money Laundering (AML) and Bank Secrecy Act (BSA) whistleblower program, what counts as potentially qualifying information, and practical steps to take when an enforcement action concludes. Rules and submission procedures can change, so check the latest guidance on the Financial Crimes Enforcement Network (FinCEN) website at fincen.gov before filing.

What Is the AML/BSA Whistleblower Program?

The program allows eligible individuals to provide information about certain violations of the BSA and potentially receive an award when that information contributes to a successful government action. The BSA requires financial institutions to maintain anti-money-laundering controls, keep certain records, and report suspicious activity. The program is administered by the U.S. Department of the Treasury through FinCEN, with the Department of Justice (DOJ) also playing a role in covered actions.

A Suspicious Activity Report (SAR) is a confidential report that a financial institution files with FinCEN when it detects activity that may involve a legal violation or appear suspicious. Whistleblowers may have information about a failure to file SARs, efforts to conceal reportable activity, or other BSA-related misconduct. The program is not a general reward for reporting any financial wrongdoing: the conduct and government action must fit the law’s requirements.

The AML/BSA program is distinct from other whistleblower programs, such as those administered by the Securities and Exchange Commission or the Commodity Futures Trading Commission. A person may have information relevant to more than one agency, but should not assume that filing with one program satisfies another program’s rules or deadlines.

Legal Origin and Timeline

Congress created the modern BSA whistleblower award framework in the Anti-Money Laundering Act of 2020. Congress later amended it through the Anti-Money Laundering Whistleblower Improvement Act, included in the National Defense Authorization Act for Fiscal Year 2023. President Biden signed that act on December 23, 2022.

The amended law provides for awards in certain cases where an eligible whistleblower’s original information leads to a covered action resulting in monetary sanctions collected above the statutory threshold. The award is generally set at 10% to 30% of monetary sanctions collected in the covered action or related actions, subject to the statute and applicable rules. The exact award is determined by the government; no percentage or payment is guaranteed.

For a claimant, the key point is that the enforcement action and the award claim are separate steps. A government announcement, settlement, or court order may show that an action has concluded, but it does not itself establish your eligibility, prove that your information contributed, or complete your claim.

What Does “Original Information” Mean?

“Original information” is a central requirement. In practical terms, it means information based on your independent knowledge or analysis that was not already known to the government from another source, and that you provided through the required process. Information does not have to be the only reason for an investigation to matter. It may help authorities open an inquiry, identify a person or account, understand a scheme, or support additional charges or sanctions.

For example, imagine an employee notices that a bank repeatedly avoids filing SARs on transactions linked to a network of shell companies. The employee gives FinCEN specific dates, account identifiers, internal escalation history, and an explanation of how managers overrode monitoring alerts. If that information is new to the government and helps establish a BSA violation, it may support a claim that the whistleblower’s original information contributed to the action.

By contrast, a general statement that “the bank has weak controls,” without specific facts, may be less useful. Information already reported in public news or contained in a government filing may not qualify as original on its own. The rules can be fact-specific, including when a whistleblower’s analysis combines public information with independent knowledge.

Which Violations May Qualify?

The program concerns violations of the BSA and related requirements. Potentially relevant conduct may include:

SAR failures: failing to file required SARs, filing them late, or submitting materially incomplete reports.
SAR confidentiality or tipping off: improperly disclosing the existence of a SAR or unlawfully alerting a subject to a report or investigation.
Structuring: breaking transactions into smaller amounts to evade reporting or recordkeeping requirements.
Customer due diligence (CDD): failures in required customer identification, beneficial-ownership, or ongoing monitoring practices.
Records and reporting: failures involving required records, transaction reports, or other BSA obligations.
Sanctions-related conduct: transactions involving sanctioned parties may be relevant when the facts also establish a qualifying BSA violation or otherwise fall within a covered action.

Important distinction: A sanctions case is not automatically a BSA whistleblower case. U.S. sanctions violations are often handled under separate authorities, including by the Office of Foreign Assets Control. The BSA program’s award provisions apply only when the action and underlying violations meet the program’s legal requirements. Likewise, a SAR’s existence does not itself prove a violation; the issue may be a failure to file, improper disclosure, or another qualifying act.

How to Handle the Award Claim Process

If an enforcement action has ended, use the following checklist. Confirm the current FinCEN instructions because filing channels, forms, and deadlines may depend on openclassactions.com the applicable rules and the type of action.

Identify the action and the authority involved.
Locate the final order, judgment, settlement, or official announcement. Note the agency or court, case name, docket or release number, date, and parties. Determine whether the action appears to involve a BSA violation and whether FinCEN, Treasury, or DOJ was involved.
Check the award-claim deadline immediately.
Do not assume that the date a news story appeared—or the date you learned of the result—is the controlling date. The applicable rules may tie the deadline to a public notice or other official event. Find the current deadline in FinCEN’s whistleblower instructions and record it. If the deadline is unclear, seek advice promptly rather than waiting for an agency response.
Find the required claim form and filing instructions.
Use FinCEN’s official website, not an unofficial form or a link sent by an unknown person. Follow the current instructions for submitting an award application and identifying the covered action. A prior tip or interview may not substitute for a separate award claim.
Explain how your information contributed.
Connect your original submission to the action’s investigation or outcome. Be specific about what you provided, when you provided it, how you submitted it, and why it was not already known. Identify relevant communications or submission confirmations if you have them.
Describe the sanctions collected, not just announced.
Distinguish between a penalty that was proposed, ordered, or agreed to and money that was actually collected. The award calculation depends on the legal rules and the monetary sanctions collected in qualifying actions; a headline figure or settlement amount may not equal the amount used for that calculation.
Keep a careful record of your claim.
Save a copy of the completed application, proof of submission, relevant public action documents, and any correspondence with the agency. Keep records securely and avoid circulating confidential materials unnecessarily.

Information to Organize Before Filing

Preparing a clear chronology can make it easier to explain your contribution. Organize facts and documents you lawfully possess, but do not remove, copy, or disclose restricted records without advice. SARs and information revealing that a SAR exists are subject to strict confidentiality protections. Do not attach a SAR or disclose its existence to an unauthorized person simply to strengthen a claim. Ask a whistleblower attorney how to handle potentially protected material.

Item Why it may help Initial submission date and method Helps establish when and how you provided information to the government. Specific facts you reported Shows what was original, concrete, and potentially useful to investigators. Follow-up communications May document interviews, additional information, or agency requests. Public enforcement documents Helps identify the covered action, legal basis, and announced outcome. Contribution timeline Allows you to compare your report with the investigation and action chronology.

How the Award Amount Is Considered

The statutory framework generally provides for an award of 10% to 30% of monetary sanctions collected in qualifying covered actions, when the legal threshold and other requirements are met. The government determines the amount under the applicable law and rules. Factors may include the significance and usefulness of the information, the assistance provided, and any other criteria established by the program.

“Sanctions collected” is different from “sanctions imposed.” If an agency announces a large penalty but collects only part of it, that difference can matter. Collection timing, related actions, and the legal classification of particular payments may also affect the analysis. Do not estimate an award by multiplying a press-release figure by a percentage and treating the result as promised compensation.

There may also be statutory or administrative limits on awards and on the funds available to pay them. Check current FinCEN guidance for the status of the program and the rules applicable to your claim. An enforcement action ending does not guarantee that the government will find a claimant eligible or make an award.

Common Mistakes to Avoid

Waiting too long: Award-claim deadlines can be strict. Confirm the trigger date and deadline promptly.
Assuming a tip automatically creates a claim: Follow the separate award application process when required.
Overstating the connection: Explain the contribution accurately; distinguish what you knew firsthand from what you inferred.
Disclosing SAR information improperly: Do not circulate SARs or reveal their existence outside authorized channels.
Confusing sanctions programs: A sanctions-related enforcement action does not automatically qualify under the BSA whistleblower program.
Using workplace systems for sensitive communications: Do not use an employer’s laptop, email, or network to contact counsel or prepare a personal claim. Use a personal device and account, while respecting legal and confidentiality obligations.

What to Do Next

Visit fincen.gov and locate the current AML/BSA whistleblower program instructions.
Identify the official enforcement action, its final date, and the applicable award-claim deadline.
Gather your original submission records and prepare a concise timeline of how your information contributed.
Do not send SARs or other restricted records casually; get advice on handling confidential material.
Consider speaking with an attorney experienced in whistleblower claims before filing, especially if you are unsure about eligibility, deadlines, or retaliation concerns.

The strongest award claim is timely, specific, and grounded in the record: what you reported, why it was original, how it helped, and which qualifying action followed. FinCEN’s current instructions and the statute—not an enforcement headline—control the award claim process.