Elizabeth Soltan Calls for Retroactive Award Eligibility in FinCEN Whistleblower Program

Elizabeth Soltan (’19), Associate at Constantine Cannon, LLP, contributed an opinion to The Hill supporting financial incentives in the emerging FinCEN whistleblower program and discussing how, in contrast with the SEC program’s approach, FinCEN’s rules can be written to provide for retroactive award eligibility (“Whistleblowers Deserve Remuneration — All of Them.” June 12). “Regardless of when they take the bold step of contacting the government, whistleblowers risk financial and emotional ruin — and sometimes even their physical safety — to bring truth to light. Retroactive award eligibility recognizes that fact. . . . Limited retroactivity, with a well-defined scope, would avoid letting brave but calendrically unlucky whistleblowers fall through the cracks.”