As the United States has ramped up sanctions regimes against countries it sees as bad actors, the federal whistleblower program designed to support those who report overseas violations is expected to soon begin rulemaking for the complicated—and valuable—process of disclosure. 

The Department of the Treasury’s Financial Crimes Enforcement Network, FinCEN, was empowered in 2020 under the Anti-Money Laundering Act to develop a new system for reporting  violations of banking laws internationally. With advocates arguing there’s billions of dollars flowing through illegal systems, and a road map for rulemaking created by the Dodd-Frank Act more than a decade earlier, whistleblower attorneys are champing at the bit for final guidance.