How do I file a whistleblower report under the Bank Secrecy Act?

Whistleblowers under the Bank Secrecy Act (BSA) can file a claim by submitting information to the Financial Crimes Enforcement Network, or “FinCEN,” which oversees the program. FinCEN has not yet issued regulations creating a process for filing BSA whistleblower claims.

The BSA whistleblower program is modeled on a program created by the Securities and Exchange Commission (SEC) in 2010. FinCEN has instructed whistleblowers to follow the SEC’s procedures until FinCEN issues BSA specific guidance.

BSA whistleblowers should provide the information identified on the SEC’s tip, complaint, or referral form. That includes information about: (1) the whistleblower (unless reporting anonymously), (2) the individuals or entities believed to have violated the BSA, (3) the conduct at issue, and (4) the sources of evidence the whistleblower either possesses or knows exist.

After the whistleblower makes an initial disclosure, FinCEN assigns a tracking number to the case. FinCEN’s Office of the Whistleblower conducts an initial review of whistleblower allegations. The Office of the Whistleblower also makes referrals to FinCEN’s Enforcement Division and other government agencies, such as the Department of Justice.

To learn more about the Bank Secrecy Act and other whistleblower programs, go to www.mololamken.com and follow us on LinkedIn. “Brilliant lawyers with courtroom savvy” — Benchmark Litigation. Copyright MoloLamken LLP 2025.