The Department and Justice (DOJ) and Financial Crime Enforcement Network (FinCEN) actively take enforcement actions against individuals and companies that violate anti-money laundering (AML) laws and Bank Secrecy Act (BSA) regulations. To strengthen these efforts, Congress included a robust whistleblower reward program in the Anti-Money Laundering Act (AMLA) of 2020. The AMLA Whistleblower Reward Program requires the Department of the Treasury (Treasury) to provide monetary awards to whistleblowers who voluntarily provide original information that leads to successful enforcement actions for AML violations.

The AMLA whistleblower law is posed to be a game changer in AML enforcement, enhancing national security by combating illicit financing, including money laundering through banks and cryptocurrency companies. Under the AMLA Whistleblower Reward Program, whistleblowers may receive awards of between 10% and 30% of the monetary sanctions collected in successful enforcement actions. Given the potential for significant fines in AML enforcement actions, whistleblowers have a strong incentive to report AML violations. Additionally, whistleblowers can submit tips anonymously if represented by an attorney.

This article outlines recent enforcement actions for AML violations and explains how whistleblowers can report AML violations and qualify for whistleblower awards.

Recent Enforcement Actions for AML Violations

TD Bank Agrees to Pay $1.8 Billion for Violations of the BSA and Money Laundering

On October 10, 2024, the DOJ and FinCEN announced that TD Bank agreed to pay over $1.8 billion in penalties to resolve investigations into BSA and money laundering violations. This penalty marks the largest-ever fine under the BSA and the largest penalty against a depository institution in U.S. Treasury and FinCEN history.

The DOJ and FinCEN’s investigations revealed that TD Bank failed to maintain an adequate AML program for nearly a decade, allowing criminals to launder hundreds of millions of dollars through its systems. TD Bank neglected to update its compliance measures, prioritizing cost-cutting and customer convenience over legal obligations. Between 2018 and 2024, nearly 92% of TD Bank’s transaction volume went unmonitored, totaling about $18.3 trillion. Consequently, three major money laundering networks moved more than $670 million through TD Bank accounts from 2019 to 2023, with employees even accepting bribes to facilitate illegal transactions.

OKX Crypto Exchange Pays More Than $504 Million for AML Violations

On February 24, 2025, OKX, a major cryptocurrency exchange, pleaded guilty to operating an unlicensed money-transmitting business and agreed to pay over $504 million in penalties.

In the DOJ’s press release announcing the enforcement action, the Acting U.S. Attorney said:

For over seven years, OKX knowingly violated anti-money laundering laws and avoided implementing required policies to prevent criminals from abusing our financial system. As a result, OKX was used to facilitate over five billion dollars’ worth of suspicious transactions and criminal proceeds. Today’s guilty plea and penalties emphasize that there will be consequences for financial institutions that avail themselves of U.S. markets but violate the law by allowing criminal activity to continue.

The DOJ’s investigation found that since 2017, OKX had:

• Facilitated over $1 trillion in transactions involving U.S. customers.
• Enabled more than $5 billion in suspicious and illicit financial activity.
• Failed to implement AML laws, including Know-Your-Customer (KYC) measures.
• Allowed customers to bypass verification through VPNs and false information.

Emphasizing the consequences for financial institutions that disregard U.S. regulations, the FBI Assistant Director stated:

Blatant disregard for the rule of law will not be tolerated, and the FBI is committed to working with our partners across government to ensure that corporations that engage in this type of conduct are held accountable for their actions.

How to Report Anti-Money Laundering Violations and Earn a Whistleblower Award

Under the AMLA, the Treasury shall pay an award to whistleblowers who voluntarily provide original information to

• their employer,
• the Secretary of the Treasury, or
• the Attorney General,

and their information leads to a successful enforcement action with monetary sanctions exceeding $1 million. Whistleblower awards range from 10% to 30% of the monetary sanctions collected in the enforcement actions.

Prior to submitting a tip, whistleblowers should consult with an experienced whistleblower attorney and review the AMLA whistleblower law to, among other things, understand eligibility rules and consider the factors that can significantly increase or decrease the size of a future whistleblower award.