FinCEN Solicits Whistleblowers on Iran-Related Sanctions Evasion and Illicit Finance

FinCEN issued a whistleblower bulletin, tied to Operation Economic Outcast, encouraging both U.S. and non-U.S. individuals to report suspected BSA and OFAC sanctions violations involving Iran, including conduct by Iranian proxies and facilitators operating outside Iran, so long as the underlying sanctions violation has a U.S. nexus. The bulletin flags typologies to watch for, including the use of high-risk jurisdictions such as Iraq, the UAE, Türkiye, and China, shipping document irregularities meant to obscure vessel identity or Iranian origin, digital asset payments tied to Iran-linked exchanges or front companies, and unusual exchange-house activity inconsistent with normal commercial patterns, as well as terrorist-financing indicators. Whistleblowers whose tips lead to a successful enforcement action yielding penalties over $1,000,000 may receive an award of 10 to 30 percent of the amount collected.