Samuel Sackey v. United States

N OTE: This disposition is nonprecedential.
United States Court of Appeals
for the Federal Circuit
______________________
SAMUEL SACKEY,
Plaintiff-Appellant
v.
UNITED STATES,
Defendant-Appellee
______________________
2025-1934
______________________
Appeal from the United States Court of Federal Claims
in No. 1:24-cv-01223-MHS, Chief Judge Matthew H. Sol-
omson.
______________________
Decided: April 16, 2026
______________________
S AMUEL SACKEY , Adelanto, CA, pro se.
P ATRICK ANGULO, Commercial Litigation Branch, Civil
Division, United States Department of Justice, Washing-
ton, DC, for defendant-appellee. Also represented by
P ATRICIA M. MCCARTHY , BRETT SHUMATE, F RANKLIN E.
WHITE, J R.
______________________
Before P ROST , BRYSON, and REYNA, Circuit Judges.
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SACKEY v. US 2
P ER CURIAM .
Mr. Samuel Sackey sued the United States in the
United States Court of Federal Claims seeking a whistle-
blower award under an anti-money laundering statute,
31 U.S.C. § 5323. The Claims Court dismissed
Mr. Sackey’s complaint for lack of jurisdiction. We affirm.
BACKGROUND
Mr. Sackey worked at JPMorgan Chase & Co. as a
Global Financial Crime Compliance Officer. Between Au-
gust 2023 and January 2024, while an employee of JPMor-
gan Chase, Mr. Sackey provided whistleblower
information to the Financial Crimes Enforcement Network
(“FinCEN”) of the U.S. Department of the Treasury
(“Treasury”). The information related to alleged deficien-
cies in JPMorgan Chase’s financial crime transaction mon-
itoring system. In August 2023, FinCEN advised
Mr. Sackey that it was tracking the matter.
Between March and May of 2024, the government ini-
tiated three enforcement actions against JPMorgan Chase.
J.A. 7; J.A. 21–40. The enforcement actions resulted in
substantial civil monetary penalties against JPMorgan
Chase. J.A. 16; J.A. 26; J.A. 36. In June 2024, Mr. Sackey
submitted a request to FinCEN asserting entitlement to a
monetary award under FinCEN’s whistleblower program.
FinCEN informed Mr. Sackey that “a response to and/or
disposition of” his application for an award “may not occur
until after the promulgation of program regulations.”
J.A. 7.
In August 2024, Mr. Sackey filed suit against Treasury
in the United States Court of Federal Claims (“Claims
Court”). His complaint alleged that the Claims Court had
subject matter jurisdiction under the Tucker Act, 28 U.S.C.
§ 1491. The complaint also alleged that the money-man-
dating source of law for section 1491(a)(1) jurisdiction was
an anti-money laundering statute, 31 U.S.C. § 5323(b). His
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SACKEY v. US 3
complaint alleged that he provided information to FinCEN
that resulted in successful enforcement actions against
JPMorgan Chase. As a result, he alleged that pursuant to
31 U.S.C. § 5323(b)(1), he is entitled to ten to thirty percent
of the total penalty amount of $448,167,980 charged to
JPMorgan Chase, or $44,000,000 to $134,000,000.
The government moved to dismiss Mr. Sackey’s com-
plaint for lack of subject matter jurisdiction. The Claims
Court granted the motion and dismissed the complaint.
J.A. 6–13. The Claims Court concluded that although the
anti-money laundering statute that Mr. Sackey relied on,
31 U.S.C. § 5323, is “money-mandating” for purposes of
Tucker Act jurisdiction, the statute’s administrative and
judicial review scheme of relief displaces the Claims
Court’s jurisdiction. J.A. 9–13.
Mr. Sackey appeals. We have jurisdiction under
28 U.S.C. § 1295(a)(3).
STANDARD OF REVIEW
We review de novo the Claims Court’s dismissal of a
complaint for lack of jurisdiction. Winnemucca Indian Col-
ony v. United States, 156 F.4th 1339, 1346 (Fed. Cir. 2025).
We also review de novo the legal determinations of the
Claims Court, including its interpretation of statutes. Ad-
kins v. United States, 960 F.3d 1352, 1361 (Fed. Cir. 2020).
D ISCUSSION
The issue before us is whether the Claims Court has
jurisdiction over Mr. Sackey’s claim that Treasury improp-
erly denied him a whistleblower monetary award under
31 U.S.C. § 5323.
I.
Section 5323 is an anti-money laundering statute, in-
troduced in its current form by the Anti-Money Laundering
Act of 2020 and amended by the Anti-Money Laundering
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SACKEY v. US 4
Improvement Act of 2022.1 In general, section 5323 pro-
vides a whistleblower program that offers incentives and
protection to individuals who provide information about vi-
olations of financial laws, here the Bank Secrecy Act. See
generally 31 U.S.C. § 5323. In relevant part, the statute
provides that the Secretary of Treasury (“Secretary”) is re-
quired to pay an award to whistleblowers who voluntary
provide information that led to monetary sanctions exceed-
ing $1,000,000 against entities deemed to have violated the
law. Id. §§ 5323(a), (b). A whistleblower’s award can be
significant, between ten and thirty percent of the total
amount sanctioned in an enforcement action. Id. § 5323(b).
Determinations on “whether, to whom, or in what amount
to make awards, shall be in the discretion of the Secretary.”
Id. § 5323(f)(1); see also id. § 5323(c)(1)(A). The “criteria”
for determining the amounts of these awards include the
significance of the information provided by the whistle-
blower, the degree of assistance provided by the whistle-
blower, Treasury’s interest in deterring violations, and
additional factors to be established by regulation.
Id. § 5323(c)(1)(B).
The statute authorizes the Secretary “to issue such
rules and regulations as may be necessary or appropriate
to implement the provisions of [section 5323] consistent
with the purposes of [that] section.” Id. § 5323(i). The Sec-
retary, however, has not promulgated any rules or regula-
tions directed to the FinCEN program and, as a result, has
not made any awards. FinCEN has asserted that awards
1 These acts were enacted into law as parts of the
National Defense Authorization Act and the Consolidated
Appropriations Act, respectively. National Defense Au-
thorization Act of 2021, Pub. L. No. 116-283, 134 Stat.
4598–603; Consolidated Appropriations Act of 2023,
Pub. L. No. 117-328, 136 Stat. 5536–38.
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SACKEY v. US 5
will be forthcoming once it promulgates necessary regula-
tions.2
II.
The government argues that the Claims Court’s Tucker
Act jurisdiction is preempted by section 5323. We agree.
Generally, the Claims Court’s jurisdiction is provided
in the Tucker Act, 28 U.S.C. § 1491. The Tucker Act waives
the government’s sovereign immunity “for certain damages
suits” against the government. Maine Cmty. Health Op-
tions v. United States, 590 U.S. 296, 322 (2020). This in-
cludes, pursuant to section 1491(a)(1), monetary relief on
claims against the government brought under “money-
mandating statutes.” Roth v. United States, 378 F.3d 1371,
1384 (Fed. Cir. 2004). Section 1491(a) of the Tucker Act
does not create a substantive cause of action, and it re-
quires a plaintiff to base its suit on a separate money-man-
dating law. Id. Here, Mr. Miller relies on 31 U.S.C. § 5323
as that separate money-mandating law.
We agree with the Claims Court that 31 U.S.C. § 5323
is a money-mandating statute.3 A statute is money man-
dating “if it can fairly be interpreted as mandating compen-
sation by the Federal Government for the damage
sustained.” Maine Cmty., 590 U.S. at 322 (citation modi-
fied). Section 5323 meets that requirement. The statute
2 See https://www.fincen.gov/whistleblower-program
(“FinCEN plans to publish a regulation to fully implement
31 U.S.C. § 5323, as amended by the Anti-Money Launder-
ing Act of 2020 and the Anti-Money Laundering Whistle-
blower Improvement Act, 2022. Once that regulation is
finalized, FinCEN will begin processing and paying
awards.”).
3 The government argued that section 5323 is not
money-mandating before the Claims Court, J.A. 11, but it
does not raise this on appeal.
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SACKEY v. US 6
requires the government to pay monetary awards when
certain statutory requirements are met. 31 U.S.C.
§ 5323(b)(1) (“[T]he Secretary . . . shall pay an
award . . . .”). The statute identifies the amount to be paid,
and provides criteria for determining the precise amount
within that range. Id. § 5323(b)(1), (c)(1). “The fact that
the Secretary retains some discretion to determine the
amount of an award, within prescribed limits, does not pre-
clude the statute from being money mandating.” Doe v.
United States, 100 F.3d 1576, 1582 (Fed. Cir. 1996).
But the Claims Court’s jurisdiction over claims based
on money-mandating statutes is not absolute. It is estab-
lished that “statutory schemes with their own remedial
framework exclude alternative relief under the general
terms of the Tucker Act.” United States v. Bormes,
568 U.S. 6, 13 (2012); accord Hinck v. United States,
550 U.S. 501, 506 (2007). In St. Vincent’s, for example, we
held “[b]ecause the Medicare Act contains its own compre-
hensive administrative and judicial review scheme, there
is no Tucker Act jurisdiction over Medicare reimbursement
claims.” St. Vincent’s Med. Ctr. v. United States,
32 F.3d 548, 549–50 (Fed. Cir. 1994). And in Vereda, we
held the Claims Court’s jurisdiction was “preempted” when
the “statutory scheme established by the Controlled Sub-
stances Act provides complete administrative review by
DEA and judicial review in district court.” Vereda, Ltda. v.
United States, 271 F.3d 1367, 1375 (Fed. Cir. 2001).
Here, section 5323 provides its own comprehensive ad-
ministrative and judicial review scheme. Subsection (f) es-
tablishes the framework for “appeals.” 31 U.S.C. § 5323(f).
It provides that the Secretary has discretion to decide
“whether, to whom, or in what amount to make awards.”
Id. § 5323(f)(1). Appeals from these determinations, except
the determination of the amount of an award if the award
complies with the provisions of the statute, “may” be
brought to the “appropriate court of appeals of the United
States not more than 30 days after the determination is
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SACKEY v. US 7
issued by the Secretary.” Id. § 5323(f)(2)(A). The statute
also provides its own standard of review for the appeal.
Id. § 5323(f)(2)(B) (citing 5 U.S.C. § 706). That standard of
review provides, for example, that the reviewing court shall
“set aside agency action, findings, and conclusions” found
to be “arbitrary, capricious, an abuse of discretion, or oth-
erwise not in accordance with law” or “unsupported by sub-
stantial evidence.” 5 U.S.C. § 706(2).
Because section 5323 provides its own administrative
and judicial review process, it preempts the Claims Court’s
jurisdiction even though section 5323 is a money-mandat-
ing statute. Thus, the Claims Court lacks authority to
grant the monetary relief that Mr. Sackey seeks.
The Claims Court also lacks jurisdiction over
Mr. Sackey’s prayer for injunctive or declaratory relief.
The Claims Court cannot order Treasury to issue regula-
tions or rule on Mr. Sackey’s whistleblower claim because
it generally lacks jurisdiction over claims seeking injunc-
tive or declaratory relief. Alvarado Hosp., LLC v. Price,
868 F.3d 983, 999 (Fed. Cir. 2017). We have considered
Mr. Sackey’s remaining arguments and find them without
merit.
CONCLUSION
We affirm the Claims Court’s dismissal of Mr. Sackey’s
complaint for lack of jurisdiction.
AFFIRMED
COSTS
No costs.
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