The Financial Crimes Enforcement Network (FinCEN) published a Notice of Proposed Rulemaking (the NPRM)1 on April 1, 2026, that would establish a comprehensive whistleblower incentive and protection program covering violations of anti-money laundering (AML) ru…
Davis Polk Discusses FinCEN Whistleblower Program
FinCEN proposed a new whistleblower program rule in April 2026 to incentivize reporting of AML violations, exposing financial institutions to increased internal and external whistleblower risks. The program could lead to legal, reputational, and operational consequences for banks, fintech, and cryptocurrency firms failing to comply with AML regulations.