The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has proposed implementing rules for the Anti-Money Laundering Whistleblower Improvement Act of 2022 (AML WIA) — and the public comment period closes June 1, 2026.

Congress passed the AML WIA to extend the proven Dodd-Frank whistleblower model — which has recovered more than $6.3 billion in sanctions since 2010 — to combat global money laundering, terrorist financing, drug-cartel networks, and sanctions evasion.

Whistleblower advocates have called it the most comprehensive award program ever passed. But Kohn, Kohn & Colapinto (KKC) and the National Whistleblower Center (NWC) warn that FinCEN’s proposed rules, published April 1, 2026, depart from congressional intent and could disqualify the very insiders the law was designed to incentivize.

Three Critical Failures in the Proposed Rules

After a comprehensive review, KKC and NWC identified three fundamental problems:

• Technical traps that punish good-faith whistleblowers. The proposed rules require whistleblowers to file an initial report on a specific government form before doing almost anything else — including contacting a journalist, reporting to their employer, or alerting an NGO or foreign law enforcement agency. That narrow definition of “voluntary” reporting conflicts with how whistleblowers actually operate, and with the plain text of the AML WIA.
• International whistleblowers left exposed. Money laundering is a transnational crime,...

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