Tell FinCEN that They Must Adopt Rules for AML WIA that Match What Congress Passed

How to Submit Your Comment

Comment Template

• Comment Template

  Re: Proposed Rules Implementing the Anti-Money Laundering Whistleblower Improvement Act

  Docket: FINCEN-2026-0067

  My name is [YOUR NAME]. I am [a concerned citizen / a supporter of anti-corruption efforts / briefly describe your connection to this issue].

  I am writing because FinCEN’s proposed rules implementing the Anti-Money Laundering Whistleblower Improvement Act would severely weaken the law. Congress passed this law to reward and protect the people who come forward with information about money laundering, terrorist financing, and financial crime. The proposed rules fall short of that mandate.

  I urge FinCEN to adopt the AML rulemaking comment submitted by the National Whistleblower Center. I am particularly concerned that the rules fail to implement the mandatory confidentiality requirements essential for the law to work, create technical procedural barriers that disqualifying good-faith whistleblowers, fail to protect international whistleblowers who face severe dangers, and add disqualifications that Congress never authorized.

  FinCEN should implement regulations that fully support American and international whistleblowers who risk their jobs, careers, and safety by alerting the authorities to corrupt financial transactions through media reports, working with anti-corruption organizations, disclosing violations to their employer, or reporting directly to the government.

  The people who expose money laundering, transnational organized crime, and violations of the Bank Secrecy Act deserve meaningful protection. I urge FinCEN to get these rules right.

  Sincerely,

  [YOUR NAME]
  [CITY, STATE — optional]
  [ORGANIZATION, if any — optional]

• NGO / Advocacy Professional

  Re: Comments on Proposed Rules, Anti-Money Laundering Whistleblower Improvement Act

  On behalf of [ORGANIZATION NAME / myself], I submit these comments in response to FinCEN’s proposed rules implementing the Anti-Money Laundering Whistleblower Improvement Act (AML WIA), 91 Fed. Reg. 16328 (April 1, 2026).

  [ORGANIZATION NAME / I] support strong and effective implementation of the AML WIA. The proposed rules, however, fall short of Congressional intent in several critical respects.

  First, the proposed definition of “voluntary” reporting is overly restrictive and inconsistent with the statute. Whistleblowers who report to employers, NGOs, news media, or foreign law enforcement before filing a government form should not be disqualified. Congress explicitly recognized diverse reporting channels in 31 U.S.C. § 5323.

  Second, the proposed rules fail to address the specific circumstances of international whistleblowers, who lack U.S. anti-retaliation protections and face grave physical risks. These are often the most critical sources of information on transnational financial crime.

  Third, the proposed rules disqualify categories of persons — including foreign officials and compliance officers — that Congress did not exclude. Under Loper Bright Enterprises v. Raimondo (2024), agencies must follow the plain text of the statute.

  I urge FinCEN to revise its proposed rules to fully implement the AML WIA in accordance with Congressional intent and to maximize protections and incentives for all qualifying whistleblowers.

  Respectfully submitted,

  [YOUR NAME]
  [TITLE]
  [ORGANIZATION]
  [EMAIL — optional]

• Industry Insider / Potential Whistleblower

  Re: Proposed AML Whistleblower Rules — Docket FINCEN-2026-0067

  My name is [YOUR NAME].

  I work in [financial services / compliance / banking / a related field — describe briefly without compromising your identity]. I am submitting this comment because the rules FinCEN is proposing would make it harder — not easier — for people like me to come forward with information about financial crime.

  The proposed rules require that a whistleblower file a specific government form before taking almost any other action. In practice, that is not how people discover and report wrongdoing. People report to supervisors. They contact lawyers. They reach out to journalists or regulators in other countries. Penalizing someone for doing those things first — before finding a government form — discourages reporting and protects wrongdoers.

  The proposed rules also fail to address how FinCEN will protect international sources. There is no meaningful confidentiality guarantee for someone reporting from outside the United States, and no clear path to anonymity. That is a serious gap.

  If FinCEN wants the AML whistleblower program to succeed, the rules need to be accessible, realistic, and genuinely protective. I urge FinCEN to adopt rules that reflect how whistleblowers actually work — and to honor the intent of the law Congress passed.

  [YOUR NAME]
  [LOCATION — optional]