FinCEN: FinCEN Issues Whistleblower Bulletin on Iran-Related Illicit Finance

• Individuals providing information on violations, including those involving Iranian proxies outside Iran, may be eligible for awards.
• Treasury may take enforcement actions against foreign companies and financial institutions facilitating illicit Iranian commerce.

FinCEN released a Whistleblower Bulletin to encourage the public to report violations of the Bank Secrecy Act and U.S. sanctions laws, particularly those involving Iran-related illicit finance. The bulletin highlights the eligibility for awards for individuals who voluntarily provide actionable information.

The initiative targets not only direct violations but also activities involving Iranian proxies and facilitators operating outside Iran. Treasury signaled readiness to enforce actions against foreign companies and financial institutions that support or facilitate illicit Iranian commerce.

• Review the FinCEN Whistleblower Bulletin for guidance on reporting Iran-related BSA or sanctions violations.
• Assess exposure to Iranian proxies and facilitators operating outside Iran in your institution’s customer base.
• Monitor Treasury enforcement actions under Operation Economic Outcast for updates on targeted foreign companies and financial institutions.

This development underscores FinCEN’s focus on Iran-related illicit finance and the use of whistleblower incentives to uncover violations of the Bank Secrecy Act and U.S. sanctions. Compliance officers must be vigilant in identifying transactions or relationships involving Iranian proxies, especially those operating outside Iran, as Treasury may pursue enforcement actions against both domestic and foreign entities. Proactive reporting and robust due diligence are essential to mitigate regulatory and reputational risks associated with Iran-related illicit finance.