On April 1, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (“NPRM”) titled “Whistleblower Incentives and Protections,” proposing regulations to fully implement Treasury’s statutory whistleblower bounty program. The NPRM covers violations of the Bank Secrecy Act (“BSA”), International Emergency Economic Powers Act (“IEEPA”), Trading with the Enemy (“TWEA”), and the Foreign Narcotics Kingpin Designation Act (“Kingpin Act”). The BSA generally applies to “covered financial institutions”1 while IEEPA and the other statutes underlie economic sanctions programs administered by the Office of Foreign Assets Control (“OFAC”) and the US Outbound Investment Security Program and have broad application.
At long last, the NPRM would operationalize the FinCEN whistleblower bounty program that has existed by statute for years. Combined with FinCEN’s February 13, 2026, launch of a dedicated whistleblower tip website, the NPRM provides more clarity and likely more incentive for individual whistleblowers to report violations and seek potentially life-changing bounties. Entities subject to the BSA and companies doing business in the US, with US persons or with the US financial system should review their risk management, escalation, and investigation procedures in light of the key provisions outlined below.
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