Banking and Finance Law Daily Wrap Up, BANK SECRECY ACT—Credit union council supports establishing FinCEN whistleblower program, (Jun 9, 2026)
Organizations Mentioned:Defense Credit Union Council | Financial Crimes Enforcement Network | Newpark Resources, Inc.
By Nora Macaluso
The group representing defense-affiliated credit unions offered suggestions it said would complement existing compliance measures.
The Defense Credit Union Council (DCUC) said it supports the Financial Crimes Enforcement Network’s (FinCEN) proposed rule establishing a whistleblower program to encourage reporting of potential violations of money-laundering laws.
"Credit unions serving military communities routinely encounter fraud, sanctions, and national security risks affecting servicemembers, veterans, and their families and understand firsthand the importance of safeguarding the financial system against criminal activities,” said the group, which represents credit unions affiliated with the military.
Background. The comments were in response to FinCEN’s Notice of Proposed Rulemaking to implement a whistleblower program by establishing a clear framework of incentives and protections to encourage individuals to report tips on fraud-related violations of the Bank Secrecy Act, Foreign Assets Control sanctions, and other laws (see Banking and Finance Law Daily, Mar. 31, 2026). The proposed rule includes provisions establishing protections for whistleblowers as well as procedures for whistleblowers to share information and also defines the terms of award applications and eligibility criteria. The proposal suggests a 10 percent to 30 percent award rate of collected monetary penalties for individuals whose tip leads to a successful enforcement action.
Suggestions. DCUC, in a comment letter responding to the proposal, offered some suggestions for a program that “complements existing compliance frameworks at credit unions.”
These included encouraging internal reporting by providing incentives such as FinCEN’s proposed 120-day waiting period before external reporting; protecting confidential supervisory information by clarifying that whistleblower submissions do not authorize the disclosure of protected materials; and establishing “rigorous standards and safeguards to discourage duplicative, unsupported, or bad-faith claims.”
At the same time, DCUC said, FinCEN should recognize good-faith compliance efforts, considering institutions’ corrective actions and cooperation with regulators as well as “the unique operational realities of small and mid-sized credit unions.”
“DCUC appreciates FinCEN’s commitment to protecting the financial system and combatting illegal finance,” said the comment letter, signed by the group’s chief advocacy officer, Jason Stverak. “We support the goals of the proposed whistleblower program and believe the final rule can be strengthened by preserving effective internal compliance programs, protecting confidential supervisory information, discouraging frivolous claims, recognizing good faith compliance efforts, and acknowledging the unique qualities of credit unions.”
Companies: Defense Credit Union Council
RegulatoryActivity: BankSecrecyAct CrimesOffenses OversightInvestigations