On March 25, anti-corruption attorneys, whistleblowers, key researchers, and former DOJ officials gathered in Paris, France to present a side panel at the Organisation for Economic Co-operation and Development’s (OECD) 2025 Global Anti-Corruption & Integrity Forum. The session, “Empowering Whistleblowers: Strengthening Protections in the Fight Against Corruption,” highlighted the developing global crisis in anti-corruption enforcement caused by recent changes to United States’s policy priorities, including a freeze on anti-bribery investigations. Panelists discussed emerging shifts in international whistleblower frameworks, laying out responsive solutions that foreign governments need to implement in order to bolster their anti-corruption efforts and take the lead on transnational enforcement in the wake of the U.S’s decline.
U.S whistleblower award schemes have been empirically proven to increase the accuracy and volume of whistleblower reports, which serve as the primary mode of identifying instances of corruption and fraud. Panelist Eliza Lockhart, Research Fellow at the U.K’s Royal United Services Institute (RUSI) Center for Financial Security, discussed her groundbreaking study, “The Role of Financial Rewards for Whistleblowers in the Fight Against Economic Crime,” which articulated the cultural shift needed in the U.K and Australia to enable whistleblower award schemes modeled on the highly successful U.S framework.
Lockhart stated that in the U.K, a “whistleblower’s value is intrinsically connected to their moral integrity. Requiring them to meet these frankly ridiculous and cruel standards that none of us could meet is not only impractical, it actually impedes financial crime investigations.” She concluded that “a crucial choice of North American award programs is that they prioritize the value of the information over the motivations of reporting,” and that in order to see a U.K awards scheme, the U.K must adopt an “intelligence first mindset.”
Recent announcements out of the U.K signal that the cultural shift Lockhart calls for may be underway, as the country announced a first-ever whistleblower award scheme for tax whistleblowers and a transnational partnership with France and Switzerland to enforce anti-bribery and anti-corruption laws.
Panelist Stephen M. Kohn, Co-Founder and Board Chairman of the National Whistleblower Center and leading whistleblower attorney, argued that liberal democracies must immediately take the lead on anti-corruption prosecutions following the United States’s move away from enforcement. He highlighted that the United States has been responsible for over 95% of anti-corruption enforcements worldwide and that the recent pause in Foreign Corrupt Practices Act (FCPA) enforcement has created a “world-wide crisis.”
Ahead of the session, Kohn published the article “A Reverse Marshall Plan for Anti-Corruption: Liberal Democracies Can Fill the Void Left by the Changes in U.S. Policies.” Kohn stated that, between 2011 and 2021, over 6,000 foreign whistleblowers have turned to U.S transnational whistleblower laws to report corruption and fraud. U.S transnational anti-corruption enforcements have involved, to date, over 66 international law enforcement agencies and collected over $24 billion USD from fraudulent and corrupt foreign activity.
Kohn commented “the people of the world have used our program to revolutionize foreign corruption prosecutions.” With the U.S stepping away from the plate, “the shift has to be to other liberal democracies. […] The entire formula is all laid out and the time is now.”
The panel was co-organized by the National Whistleblower Center and the UNGC PRME Working Group on Anti-Corruption. Panelists featured alongside Kohn and Lockhart included Azerbaijani whistleblower and advocate Emin Huseynov, Cambridge Analytica whistleblower Christopher Wylie, former Deputy of the IRS’s Criminal Investigation Division and Head of International Operations Eric Hylton, and panel moderator and Mexican anti-corruption attorney María de los Ángeles Estrada.
