Retaliation banned, arbitration clauses voided – is your HR team prepared?
Employees at hundreds of thousands of companies could soon earn millions for reporting financial crimes directly to the federal government.
The U.S. Treasury Department's Financial Crimes Enforcement Network, known as FinCEN, published a proposed rule on April 1, 2026, that would create a formal whistleblower program with significant financial rewards and workplace protections. The program would pay individuals between 10 and 30 percent of monetary sanctions collected in enforcement actions exceeding $1 million – meaning a single tip could translate into a multimillion-dollar payout for the person who filed it.
The reach of the proposed program is vast. FinCEN estimates that more than 291,000 financial institutions and roughly 1.8 million other businesses fall within scope. That includes banks, credit unions, insurance companies, broker-dealers, investment advisers, money services businesses, casinos, and dealers in precious metals. It also extends well beyond the financial sector to cover construction firms, manufacturers, healthcare organizations, energy companies, tech firms, shipping and logistics operators, and agricultural businesses – essentially any entity with obligations under federal anti-money laundering or economic sanctions laws.
For HR professionals, the proposed rule raises immediate compliance concerns on several fronts.
The anti-retaliation provisions would prohibit employers from...
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