Snapshot:
On March 30, 2026, FinCEN issued a Notice of Proposed Rulemaking (NPRM) to fully implement its long‑awaited AML & sanctions whistleblower rewards program. The proposal would allow eligible whistleblowers to receive 10%–30% of collected penalties tied to BSA or OFAC violations, funded through a $300 million revolving fund.
Why it Matters:
This proposal significantly raises enforcement risk for financial institutions by financially incentivizing insiders to report compliance failures directly to Treasury. BSA/AML and OFAC programs must now withstand scrutiny not just from regulators, but from employees, vendors, and third parties with direct access to systems and data. Strong documentation, controls, and issue escalation processes have never mattered more.