America’s Whistleblower Programs are a Beacon for International Whistleblowers

Constantine Cannon whistleblower partner Mary Inman and associate Liz Soltan wrote a guest post for the Taxpayers Against Fraud blog about the role of international whistleblowers in providing an increasing number of tips under the various American whistleblower reward programs.

The U.S. leads the world in enlisting whistleblowers as force-multipliers to help law enforcement and regulators detect and root out fraud and corruption. As Mary and Liz wrote, “There is no requirement that an individual be a U.S. citizen or resident to bring cases under the False Claims Act, the Foreign Corrupt Practices Act, or to submit a tip to the SEC, IRS, or any other agency whistleblower program. Whistleblowers from foreign shores can bring their information to U.S. authorities and qualify for whistleblower awards, and they do.” As head of Constantine Cannon’s international whistleblower practice, Mary and her colleagues in the firm’s London office have experienced this first-hand, having been approached by an increasing number of international whistleblowers seeking to provide information to the U.S. government via the various whistleblower programs.

The number of foreign whistleblowers is growing, with tips to the SEC from the top six foreign countries for tipsters increasing from 209 in 2012 to 717 in 2019. And welcoming foreign whistleblowers makes good business sense for America. In 2021, international whistleblowers made up 20% of SEC award recipients, showing that international tips led to many successful enforcement actions. That same year, the SEC announced a $5 million award to foreign joint whistleblowers, which means the fraud enforcement action based on their tip led to between $16.6 and $50 million in penalties. Whistleblowers from outside the U.S. can be especially helpful in cases involving the Foreign Corrupt Practices Act, which prohibits bribes by U.S. persons or companies to foreign officials.

The welcome mat is out for international whistleblowers, both in U.S. whistleblower programs and at Constantine Cannon.

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