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ARTICLE · 10 APRIL 2026

FinCEN's New Whistleblower Program: A Game-Changer For AML And Sanctions Enforcement

ArentFox Schiff
ArentFox Schiff
Contributor
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On April 1, the Financial Crimes Enforcement Network (FinCEN) submitted a Notice of Proposed Rulemaking proposing regulations to establish a formal Whistleblower Program under 31 U.S.C. § 5323.

United StatesGovernment, Public Sector
Peter Unger
Peter Unger
Alexander S. Birkhold
Alexander S. Birkhold
Elizabeth Satarov
Elizabeth Satarov

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The proposed rule would finally implement Section 6314 of the Anti-Money Laundering Act of 2020 (AML Act) and the Anti-Money Laundering Whistleblower Improvement Act of 2022, which together authorize enhanced awards and anti-retaliation protections for individuals who voluntarily report violations of the Bank Secrecy Act (BSA), the International Emergency Economic Powers Act (IEEPA), the Trading With the Enemy Act of 1917 (TWEA), and the Foreign Narcotics Kingpin Designation Act (Kingpin Act). While FinCEN had previously been accepting tips, the proposed rule would establish a detailed framework for the Whistleblower Program and allow FinCEN to process whistleblower rewards. The goal of the program is to strengthen the US government's ability to combat money laundering, terrorist financing, sanctions violations, and related financial crimes.

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