Media Coverage
Source: Global Investigations Review
Media Coverage
Press Contacts: Erik Cummins, Matt Hyams, Taina Rosa, Olivia Meyer
04.01.26
On March 30, 2026, the Financial Crimes Enforcement Network (FinCEN) announced that it would publish a long-awaited proposed rule on how the agency will reward people whose tips lead to successful enforcement actions.
The proposed rule, which was posted publicly on April 1, 2026, offers “incentives and protections” for people to report violations of the Bank Secrecy Act, sanctions, and other finance laws, FinCEN said, pointing to its recently announced whistleblower portal.
In an interview with Global Investigations Review after the announcement but prior to rule’s publication, Pillsbury partner Rich Donoghue, co-leader of the firm’s Corporate Investigations and White Collar Defense practice, noted there is some “overlap” between the incentives offered by FinCEN and similar programs at the DOJ, Commodity Futures Trading Commission, and the Securities and Exchange Commission.
“Once [the rule] is up, it will be interesting to see if there are any differences between this program and what we've seen elsewhere,” he said.
He also said that companies should immediately begin tailoring their compliance programs and create a culture where employees believe managers will take reports seriously and act on them. That could include financial incentives for employees to come forward, Donoghue added, something he said he hasn't yet seen major companies do.
They should also invest in monitoring technology and tailor their programs to track the risks within their particular industry, he said.
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