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Friday, May 15, 2026

It Takes a Rogue to Catch Rogue: Balancing Priorities in FinCEN’s Proposed AML Rule - The National Law Review

Whistleblower advocates were quick to raise the alarm about the recent proposed rule, implementing the Anti-Money Laundering Whistleblower Improvement Act (“AML WIA”). The advocates argue the rule, proposed by the Financial Crimes Enforcement Network (“FinCEN”), offers limited protections and could dampen incentives for whistleblowers. They also argue that it is not in keeping with Congressional intent and the actual language of the AML WIA.

On April 30th, the National Whistleblower Center submitted a 76-page rulemaking comment, detailing problems it found with the Proposed Rules. It strongly urged FinCEN to address these issues in its final rulemaking to ensure the effectiveness of the AML whistleblower program. This article is part of a series that will address the major issues identified by the NWC and explain why the success of FinCEN’s whistleblower program depends on their resolution before final rules are codified. To learn more about the
importance of the AML whistleblower program, check out the first article in this series. Find more information about NWC’s campaign here.

The Value of Rogues

FinCEN says the goal of the Proposed Rules is to combat money laundering, financing of terrorism, and other illicit finance activity by incentivizing insiders to come forward to US authorities with significant information about the schemes. Sometimes, whistleblowers with valuable first-hand knowledge of fraudulent conduct may be considered culpable by law enforcement due to...



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