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Saturday, May 16, 2026

FinCEN’s Proposed Rule: Implementing the Anti-Money Laundering Whistleblower Improvement Act - The National Law Review

The Financial Crimes Enforcement Network (“FinCEN”) recently issued a Proposed Rule to implement the Anti-Money Laundering Whistleblower Improvement Act (“AML WIA”). Whistleblower advocates argue that the proposed rule diverges from Congressional intent and fails to sufficiently protect or incentivize whistleblowers, undermining the law’s purpose.

On April 30th, the National Whistleblower Center submitted a 76-page comment to FinCEN, identifying how the Proposed Rules weaken the AML whistleblower program’s impact. This article begins a series examining these major issues and explaining why the program’s success depends on their resolution before finalizing the rules.,To learn more about NWC’s campaign, click here.

A Broader Scope: Why is the AML WIA important?

The Anti-Money Laundering Act established FinCEN’s whistleblower program in 2020, requiring the Department of Justice (“DOJ”) and FinCEN to accept confidential and anonymous reports from whistleblowers worldwide who disclose violations of the Anti-Money Laundering Act, the Bank Secrecy Act (“BSA”), and other related laws. The AML WIA of 2022 strengthened this program by adding incentives for whistleblowers to make disclosures, enabling whistleblowers to receive a mandatory award of between 10%-30% of the sanctions collected by FinCEN if their original information leads to a successful enforcement action. This change aligned the AML whistleblower program with other highly successful U.S. whistleblower programs (such...



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