On March 30, 2026, the Financial Crimes Enforcement Network (FinCEN) published a Notice of Proposed Rulemaking (NPRM) to operationalize its whistleblower program by creating substantial financial incentives for individuals to report violations of the Bank Secrecy Act (BSA), US sanctions laws, and related national security laws “critical to safeguarding the US financial system and national security.” The NPRM’s remarkably broad scope would reach companies with sanctions exposure, not just BSA-covered financial institutions. Comments are due June 1, 2026.

The NPRM proposes:

• Procedures for timely and secure reporting, including for submitting an award application;
• Eligibility criteria for making awards and a process to adjudicate award applications;
• Awards of “10-30 percent of collected monetary penalties for individuals whose tip leads to a successful enforcement action;” and
• Protections for whistleblowers who provide information through this program.

This Legal Update analyzes the proposed rule’s key provisions, compares the program to other federal whistleblower initiatives, and offers practical guidance for affected companies.

Statutory and Regulatory Framework

The whistleblower program is administered pursuant to 31 U.S.C. § 5323, which authorizes the Secretary of the Treasury to pay awards to compensate individuals who come forward with valuable information about financial crimes. The information must then be used in a “covered judicial or administrative action”...

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