TAF Coalition Submitted Comments on the Proposed Rules for FinCEN’s Whistleblower Program
Washington, D.C. — On June 1, 2026, The Anti-Fraud Coalition (TAF Coalition) submitted comments to the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) on the proposed rule, “Whistleblower Incentives and Protections,” 91 Fed. Reg. 16328 (Apr. 1, 2026).
In a letter submitted on June 1, 2026, to Secretary Scott Bessent and Director Andrea M. Gacki, TAF Coalition supports the Proposal, but suggests significant changes to ensure that whistleblowers are properly incentivized to report, adequately protected, and appropriately awarded in the manner intended by Congress.
TAF Coalition applauded FinCEN for including in the Proposal many common-sense provisions designed to promote the usability and flexibility of the program. The inclusion of a $15 million threshold for a 30% award presumption, for instance, builds on the structure of a highly successful amendment to the SEC’s whistleblower program, while increasing the threshold amount in recognition of the unique aspects of FinCEN’s program.
TAF Coalition raised concerns over certain policy choices in the Proposed Rules that could undermine the program from its outset, and which are unnecessary or even counterproductive to the establishment of an efficient, effective program to identify violations of the Statutes.
“The Proposed Rules mark a significant step forward in establishing a framework to encourage the reporting of financial crimes,” said TAF Coalition President and CEO, Jacklyn DeMar. “While much of the proposal is strong, critical changes must be made to the final regulations to ensure that whistleblowers are truly incentivized to come forward and protected when they do. We hope FinCEN takes these comments seriously and that the program will thrive” she continued.
Thank you to Poppy Alexander of Whistleblower Partners LLP, and Andrew Feller of Kohn, Kohn & Colapinto for their assistance in drafting the comments.
About The Anti-Fraud Coalition
The Anti-Fraud Coalition is a public interest, non-profit organization dedicated to defending and empowering whistleblowers who expose fraud on the government and the financial markets and protect public resources by empowering whistleblowers, supporting the legal community, and advocating for robust anti-fraud legislation.
