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If you work in banking, finance, or any industry where money moves across borders, you may have seen something that didn't look right: a transaction that seemed suspicious, a sanctions violation quietly swept under the rug, or funds flowing to places they shouldn't. Blowing the whistle on these matters has been possible for some time, pursuant to the Anti-Money Laundering Act and the Anti-Money Laundering Whistleblower Improvement Act, but the government is now seeking to set a formal framework for doing so.


On March 30, 2026, the U.S. Department of the Treasury's Financial Crimes Enforcement Network — known as FinCEN — announced a proposed rule that would establish a program to pay whistleblowers who report certain financial crimes. This is one of the most important developments in financial fraud enforcement in years, and if you have information about potential wrongdoing, now is the time to pay attention.


What Is FinCEN and Why Does This Matter?
FinCEN is the federal agency responsible for safeguarding the U.S. financial system from certain forms of illicity financial activity, such as money laundering and terrorist financing. The agency has long had the authority to collect whistleblower tips, but until now, it lacked a fully operational framework for doing so. This proposed rule changes that.


What Kind of Wrongdoing Is Covered?
The proposed program covers violations of the Bank Secrecy Act, U.S. sanctions programs administered by the Office of Foreign Assets Control (OFAC), and several other laws designed to protect the integrity of the American financial system and national security. In plain terms, this includes things like banks failing to report suspicious transactions, companies doing business with sanctioned countries or individuals, and fraud schemes that exploit the financial system.
How Much Could a Whistleblower Be Paid?

The proposed rule would allow FinCEN to award whistleblowers between 10 and 30 percent of the monetary penalties collected in a successful enforcement action, as long as the tip was what led authorities there.

What Protections Would Whistleblowers Have?
The proposed rule also includes protections for whistleblowers who come forward. Retaliation against employees who report violations is a serious concern, and the program is designed to address that. The underlying statutes — the Anti-Money Laundering Act of 2020 and the Anti-Money Laundering Whistleblower Improvement Act of 2022 — provide the legal foundation for these protections.


What Should You Do If You Have Information?
FinCEN is accepting tips, now through its new whistleblower portal, while the rule is being finalized. The agency has specifically encouraged people to come forward as soon as possible and to bring detailed, specific documentation.
Before you submit anything, you should speak with an attorney who handles whistleblower cases. The decisions you make early in this process — what to submit, how to submit it, and how to protect yourself — can have a major impact on both your tip and the size of any award you may receive. Our firm represents whistleblowers and can help you understand your options confidentially. Contact us today.


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