FinCEN Whistleblower Bulletin: Iran-Related Illicit Finance

The U.S. Department of the Treasury’s (Treasury) Financial Crimes Enforcement Network (FinCEN) maintains a whistleblower incentive program for members of the public to submit information about violations of certain statutes enforced by Treasury and the Department of Justice (DOJ), including the Bank Secrecy Act (BSA) and the national security laws that serve as the foundation for the U.S. trade and economic sanctions administered by Treasury’s Office of Foreign Assets Control (OFAC). By reporting information about suspected Iran-related violations of the BSA and economic sanctions, whistleblowers help strengthen our national security and keep America safe. FinCEN welcomes tips from both U.S. and non-U.S. whistleblowers regarding individuals or entities that may be violating the BSA or OFAC-administered sanctions programs. This includes information about violations of these authorities that may involve the use of Iranian proxies and facilitators operating outside of Iran. Potential violations of OFAC sanctions require a nexus to the United States, including direct or indirect transactions with or involving the United States, U.S. persons, or entities owned or controlled by U.S. persons. Non-U.S. persons are also prohibited from certain dealings, including from causing U.S. persons to wittingly or unwittingly violate U.S. sanctions, conspiring to violate U.S. sanctions on Iran, and engaging in conduct that evades U.S. sanctions. Operation Economic Outcast Announced by Secretary Bessent on August 24, 2026, dubbed Economic D-Day, Operation Economic Outcast is severing the remaining economic lifelines that sustain the Iranian regime. Treasury has mapped the networks, facilitators, and financial channels that Iran uses to smuggle oil, evade sanctions, and fund terror. Working with partners across the U.S. government, the European Union, United Kingdom, Gulf partners, and others, Treasury is targeting any source of the regime’s illicit revenue, as well as its sanctions evasion schemes to move funds. Treasury warned that any entity facilitating money laundering or sanctions evasion on behalf of Iran risks being cut off from the U.S. financial system. It also expanded secondary sanctions exposure for those who continue doing business with the Iranian regime and will accelerate the pace of U.S. enforcement. More information on Operation Economic Outcast is available here. What To Look For Individuals potentially eligible for the whistleblower program may have direct knowledge of an individual or entity facilitating Iranian sanctions evasion or money laundering. FinCEN Whistleblower Bulletin:
Blow the Whistle on Iran-Related
Illicit Finance