On April 1, 2026, the Financial Crimes Enforcement Network (“FinCEN”) issued a notice of proposed rulemaking (“NPRM”) that would operationalize the whistleblower program Congress created in 2021 and expanded in 2022. The proposal would establish the procedures for submitting tips, seeking awards, and invoking statutory protections, while bringing a broader set of anti-money laundering and sanctions-related matters squarely within FinCEN's whistleblower authorities. For companies subject to the Bank Secrecy Act (“BSA”) and for businesses that operate in sanctions-sensitive sectors, the proposal is significant not simply because it promises monetary awards, but because it is designed to encourage earlier, better-documented, and potentially more frequent reporting of suspected misconduct.
What the Proposed Rule Would Do
The proposed rule would replace FinCEN's existing informant-reward regulation at 31 C.F.R. § 1010.930 with a more comprehensive “Whistleblower Incentives and Protections” regime. As FinCEN explains, the new framework is intended to govern the entire life cycle of a whistleblower submission, including: the submission of “original information”; eligibility requirements; award applications; award adjudication; confidentiality protections; and appeals, among other provisions. In other words, FinCEN is not merely creating a tip line. It is building, as required by statute, a formal program that mirrors the structure of more mature federal whistleblower regimes,...
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