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FinCEN Issues NPRM to Fully Implement Whistleblower Program
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FinCEN Issues NPRM to Fully Implement Whistleblower Program
Enforcement, International Law, Trade Policy, U.S. Department of Justice (DOJ), U.S. Office of Foreign Assets Control (OFAC)

FinCEN Issues NPRM to Fully Implement Whistleblower Program

Authors:

Jennifer Diaz, President, Diaz Trade Law

Amber Pirson, Attorney, Diaz Trade Law

FinCEN’s March 30, 2026, Notice of Proposed Rulemaking (NPRM) marks a major step toward fully operationalizing the agency’s whistleblower program, designed to incentivize reporting of Bank Secrecy Act (BSA), sanctions, IEEPA, and other illicit finance violations. The proposal outlines how whistleblowers can securely submit information, how awards will be determined, and what protections will be available.

This development reflects the Treasury Department’s broader strategy to strengthen financial system integrity and encourage actionable tips that support enforcement efforts. For financial institutions, compliance professionals, and potential whistleblowers, the NPRM provides long‑awaited clarity on program structure and expectations.

Overview of the Proposed Rule

FinCEN’s NPRM proposes a comprehensive framework for administering whistleblower submissions and awards. Key elements include:

Secure submission procedures for individuals reporting suspected violations of the BSA, OFAC sanctions, and related laws.
Eligibility criteria for whistleblower awards, including documentation requirements and timelines.
Award ranges of 10–30% of monetary penalties collected when a whistleblower’s information leads to a successful enforcement action.
Robust protections for individuals who provide information, including confidentiality and anti‑retaliation safeguards.

These provisions aim to encourage early, detailed reporting while ensuring whistleblowers are shielded from adverse consequences.

Why FinCEN Is Prioritizing Whistleblower Incentives

The NPRM aligns with Treasury’s broader […]

By Jennifer Diaz|2026-04-03T10:52:12-04:00April 3, 2026|Enforcement, International Law, Trade Policy, U.S. Department of Justice (DOJ), U.S. Office of Foreign Assets Control (OFAC)|0 Comments

Customs and Trade Law Weekly Snapshot
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Customs and Trade Law Weekly Snapshot
HTSUS, International Law, International Trade, U.S. Customs and Border Protection (CBP), U.S. Department of Commerce (DOC), U.S. International Trade Commission (USITC), U.S. Office of Foreign Assets Control (OFAC), U.S. Office of the United States Trade Representative (USTR), Uncategorized

Customs and Trade Law Weekly Snapshot

Here is a recap of the latest customs and international trade law news:

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By Jennifer Diaz|2022-12-25T23:14:25-05:00December 9, 2022|HTSUS, International Law, International Trade, U.S. Customs and Border Protection (CBP), U.S. Department of Commerce (DOC), U.S. International Trade Commission (USITC), U.S. Office of Foreign Assets Control (OFAC), U.S. Office of the United States Trade Representative (USTR), Uncategorized|0 Comments

Customs Bulletin Weekly, Vol. 56, November 16, 2022, No. 45

Below is a recap for this week’s Customs Bulletin.

African Growth and Opportunity Act (AGOA) Textile Certificate of Origin
- The African Growth and Opportunity Act (AGOA) was adopted by the U.S. with the enactment of the Trade and Development Act of 2000 (Pub. L. 106–200). The objectives of AGOA are (1) to provide for extension of duty-free treatment under the Generalized System of Preferences (GSP) to import sensitive articles normally excluded from GSP duty treatment, and (2) to provide for the entry of specific textile and apparel articles free of duty and free of any quantitative limits from eligible countries of sub-Saharan Africa.
- For preferential treatment of textile and apparel articles under AGOA, the exporter or producer is required to prepare a certificate of origin and provide it to the importer. The certificate of origin includes information such as name and address of the exporter, producer, and importer; the basis for which preferential treatment is claimed; and a description of the imported article(s). The importers are required to have the certificate in their possession at the time of the claim, and to provide it to Customs and Border Protection (CBP) upon request. The collection of this information is provided for in 19 CFR 10.214, 10.215, and 10.216.
- CBP invites the general public and other Federal agencies to comment on the proposed and/or continuing information collections pursuant to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). This proposed information collection was previously published in the Federal Register […]

By Jennifer Diaz|2022-11-18T16:33:44-05:00November 21, 2022|COVID-19, Import, International Business, International Law, International Trade, U.S. Customs and Border Protection (CBP), U.S. Office of the United States Trade Representative (USTR)|0 Comments

Customs Bulletin Weekly, Vol. 56, November 9, 2022, No. 44

Below is a recap for this week’s Custom’s Bulletin.

Proposed Revocation of Three Ruling Letters and Proposed Revocation of Treatment Relating to the Tariff Classification of Wireless Headphone Sets from China and an Undisclosed Country
- In NY N022195, NY N022204 and NY N240329, CBP classified wireless headphone sets in heading 8517, HTSUS, specifically in subheading 8517.62.00, HTSUS, which provides for “Other apparatus for transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network (such as a local or wide area network): Machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus.” CBP has reviewed NY N022195, NY N022204 and NY N240329, and has determined the ruling letters to be in error.
- It is now CBP’s position that the wireless headphone sets are properly classified in heading 8518, HTSUS, specifically in subheading 8518.30.20, HTSUS, which provides for “Microphones and stands therefor; loudspeakers, whether or not mounted in their enclosures; headphones and earphones, whether or not combined with a microphone, and sets consisting of a microphone and one or more loudspeakers; audio-frequency electric amplifiers; electric sound amplifier sets; parts thereof: Headphones and earphones, whether or not combined with a microphone, and sets consisting of a microphone and one or more loudspeakers: Other.”
Country of Origin Marking Requirements for Containers or Holders
- Section 304 of the Tariff Act of 1930, as amended, 19 U.S.C. 1304, requires each imported article of foreign origin, […]

By Jennifer Diaz|2022-11-10T12:24:52-05:00November 14, 2022|AD/CVD, Country of Origin, Customs Broker, Export, Import, International Business, International Law, International Trade, U.S. Customs and Border Protection (CBP), U.S. Department of Commerce (DOC)|0 Comments

Customs Bulletin Weekly, Vol. 56, November 2, 2022, No. 43

Below is a recap for this week’s Custom’s Bulletin.

Elimination of Customs Broker District Permit Fee
- Section 641 of the Tariff Act of 1930, as amended (19 U.S.C. 1641), provides that individuals and business entities must hold a valid customs broker’s license and permit to transact customs business on behalf of others. The statute also sets forth standards for the issuance of broker licenses and permits; provides for disciplinary action against brokers in the form of suspension or revocation of such licenses and permits or assessment of monetary penalties; and, provides for the assessment of monetary penalties against other persons for conducting customs business without the required broker’s license.
- On June 5, 2020, U.S. Customs and Border Protection (CBP) published a notice of proposed rulemaking (NPRM) in the Federal Register (85 FR 34549), proposing the elimination of customs broker district permit fees in parts 24 and 111.
- Consistent with the June 5, 2020, notice, CBP is publishing a final rule to, among other things, eliminate customs broker districts (see ‘‘Modernization of the Customs Broker Regulations’’ RIN 1651–AB16). Specifically, CBP is transitioning all brokers to national permits and expanding the scope of the national permit authority to allow national permit holders to conduct any type of customs business throughout the customs territory of the United States. As a result of the elimination of customs broker districts, CBP is amending in this document the regulations to eliminate customs broker district permit fees.
Modernization of the Customs Broker Regulations
- This document adopts […]

By Jennifer Diaz|2022-11-03T10:24:11-04:00November 7, 2022|AD/CVD, Brokers, China Trade War, Customs Broker, Import, International Law, International Trade, U.S. Customs and Border Protection (CBP), U.S. Department of Commerce, U.S. Department of Commerce (DOC)|0 Comments

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