Mayerbrown FinCEN Proposes Whistleblower Program to Combat Financial Crimes
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- •FinCEN's NPRM proposes a whistleblower program with financial incentives for reporting violations.
- •The program covers a wide range of laws, including the Bank Secrecy Act and U.S. sanctions.
- •Public comments on the NPRM are due by June 1, 2026.
On March 30, 2026, FinCEN published a Notice of Proposed Rulemaking (NPRM) to implement a whistleblower program aimed at enhancing enforcement of the Bank Secrecy Act and U.S. sanctions laws. The program offers financial incentives for individuals to report violations, with awards for information leading to successful enforcement actions exceeding $1 million. The proposed rule broadens the definition of 'whistleblower' and allows for original information from non-U.S. persons. This initiative is part of a broader effort to safeguard the U.S. financial system and national security. The NPRM is open for public comment until June 1, 2026. Secretary of the Treasury Scott Bessent emphasized the importance of actionable tips in preventing fraud and illicit finance activities. FinCEN has previously accepted whistleblower tips but aims to establish more structured procedures through this NPRM.
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