A proposed rule implementing the whistleblower program from U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) could significantly increase enforcement risk for companies subject to anti-money laundering and sanctions laws—while creating powerful financial incentives for employees and third parties to report potential violations. FinCEN issued a Notice of Proposed Rulemaking on April 1, 2026, to implement the program enacted by Congress in 2020, which provides robust financial incentives and legal protections for individuals who report such violations.

Key Takeaways

• Widely applicable. The proposed rule, if adopted, would impact every company with obligations to comply with the Bank Secrecy Act and U.S. sanctions.
• Generous rewards. Awards would range between 10%–30% of monetary penalties over $1 million collected in resulting enforcement actions.
• Encourages internal reporting. Individuals who report violations first to their employers and later to FinCEN would remain eligible for rewards. This approach incentivizes internal reporting and increases pressure on companies to ensure they respond appropriately and expeditiously to compliance concerns escalated by employees.
• Special rules for control functions. Whistleblowers in the compliance and audit function, among others, would be required to wait 120 days before reporting to FinCEN, giving companies an opportunity to address and remediate internally identified violations during that...

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