FinCEN Issues NPRM to Fully Implement Whistleblower Program
Authors:
Jennifer Diaz, President, Diaz Trade Law
Amber Pirson, Attorney, Diaz Trade Law
FinCEN’s March 30, 2026, Notice of Proposed Rulemaking (NPRM) marks a major step toward fully operationalizing the agency’s whistleblower program, designed to incentivize reporting of Bank Secrecy Act (BSA), sanctions, IEEPA, and other illicit finance violations. The proposal outlines how whistleblowers can securely submit information, how awards will be determined, and what protections will be available.
This development reflects the Treasury Department’s broader strategy to strengthen financial system integrity and encourage actionable tips that support enforcement efforts. For financial institutions, compliance professionals, and potential whistleblowers, the NPRM provides long‑awaited clarity on program structure and expectations.
Overview of the Proposed Rule
FinCEN’s NPRM proposes a comprehensive framework for administering whistleblower submissions and awards. Key elements include:
- Secure submission procedures for individuals reporting suspected violations of the BSA, OFAC sanctions, and related laws.
- Eligibility criteria for whistleblower awards, including documentation requirements and timelines.
- Award ranges of 10–30% of monetary penalties collected when a whistleblower’s information leads to a successful enforcement action.
- Robust protections for individuals who provide information, including confidentiality and anti‑retaliation safeguards.
These provisions aim to encourage early, detailed reporting while ensuring whistleblowers are shielded from adverse consequences.
Why FinCEN Is Prioritizing Whistleblower Incentives
The NPRM aligns with Treasury’s broader […]
