FinCEN Issues Translated Versions of Iran Whistleblower Bulletin

FinCEN on October 26 issued Arabic, Farsi, Hindi, Mandarin, Russian, Spanish, and Turkish translations of its September 10 whistleblower bulletin on Iran-related illicit finance. The bulletin supports Operation Economic Outcast and invites information from U.S. and non-U.S. whistleblowers concerning suspected Bank Secrecy Act and sanctions violations, including activity involving Iranian proxies and facilitators outside Iran.

The English bulletin describes potential awards of 10–30 percent of collected monetary penalties when information leads to a successful Treasury or Justice Department enforcement action yielding more than $1 million, subject to statutory and regulatory requirements. Treasury may also exercise discretion to award eligible individuals working for or on behalf of the Iranian regime or Iranian state-owned enterprises.

A comparison with the English text identified material translation defects. The Farsi version displays reversed digits in award percentages and statutory references and introduces wording suggesting entrapment. The Spanish version reverses an indicator concerning charities that openly support terrorism. Russian and Turkish wording narrows references to “U.S. persons,” while Hindi omits opaque ownership from a financial-institution risk indicator. Readers should consult the English bulletin when assessing these passages.

Information on reporting tips and applying for awards is available through FinCEN’s Office of the Whistleblower.