In a notable back-to-back set of releases, the Financial Crimes Enforcement Network first issued a March 30, 2026 advisory urging financial institutions to identify and report suspicious activity tied to health care fraud schemes targeting Medicare, Medicaid, and other federal and state health care benefit programs, and then, one day later, published a notice of proposed rulemaking to formally implement its whistleblower incentives and protections program. Read together, the two actions send a clear message: FinCEN is sharpening both sides of the anti-fraud enforcement equation by giving financial institutions more specific expectations for suspicious activity reporting while also creating stronger incentives for insiders to bring forward information about Bank Secrecy Act and sanctions-related misconduct.
For banks, fintechs, money services businesses, broker-dealers, crypto-facing institutions, and other covered financial institutions, the sequencing is important. FinCEN is not merely announcing a whistleblower regime in the abstract. It is simultaneously highlighting a concrete enforcement priority—health care fraud—and describing the transactional patterns, typologies, and red flags that institutions should be watching for now. That pairing suggests that FinCEN expects not only better Suspicious Activity Reports, but also more direct reporting from insiders with actionable knowledge of compliance failures, concealed ownership structures, and financial flows tied to...
Medicare and Medicaid provide health care coverage to millions of Americans and are aggressively protected by federal and state authorities. The Department of Health and Human Services Office of In...