Executive Summary

• What’s new: The U.S. Treasury’s FinCEN issued a Notice of Proposed Rulemaking to fully implement its whistleblower incentives program.
• Why it matters: The incentives apply to any individual who provides original information about violations of U.S. bank secrecy, anti-money laundering or sanctions laws, and are not limited to U.S. bank employees or U.S. citizens. The program could increase the enforcement risk for companies subject to these laws.
• What to do next: Companies will want to review their protocols for dealing with whistleblower complaints, and their anti-money laundering and sanctions compliance procedures and related training.

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On March 30, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking (NPRM) to fully implement a whistleblower incentives program. The NPRM will be published in the Federal Register, with a 60-day public comment period. FinCEN is expected to finalize the rule following review of comments.

Scope of the Whistleblower Program

FinCEN’s whistleblower program is drafted to apply broadly to any individual with qualifying information, not just U.S. bank employees or U.S. citizens. The program applies to any individual who voluntarily provides original information about violations (or conspiracies to violate) the Bank Secrecy Act, U.S. anti-money laundering (AML) laws, or U.S. sanctions laws. To be eligible for an award, information provided...

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