06/09/2026
📄On May 29, Constantine Cannon submitted comments to the recently proposed rulemaking for the FinCEN AML/Sanctions Whistleblower Program, drafted by Constantine Cannon whistleblower partners Marlene Koury and Gordon Schnell. Koury and Schnell “applaud[ed] FinCEN for how it has managed the Whistleblower Program so far,” underscoring how “receptive and responsive” the agency has been and how it has “consistently treated our whistleblower-clients with respect and appreciation for coming forward.”
Koury and Schnell carefully reviewed the proposed rules with the aim of identifying any changes or improvements they think would make the FinCEN program as successful as possible. In particular, they “focused on ensuring that whistleblowers are best protected and incentivized in coming forward given the significant risks they face of retaliation and social isolation for doing so.”
Learn more about some of the key recommendations they offered in our blog post:
https://constantinecannon.com/whistleblower/constantine-cannon-submits-comments-to-proposed-rulemaking-for-fincen-aml-sanctions-whistleblower-program/