The petitioner in John Doe v. SEC gave a tip about a foreign bribery scheme to a journalist, who published articles on the subject and passed the information to the DOJ. In a 2-1 decision, the D.C. Circuit held that Doe did not qualify for an award because he did not submit his information to the SEC for nearly a year after contacting the media, and his formal submission did not help the investigation (as the SEC already had his information from the press and DOJ).

The Dodd-Frank Act grants awards to whistleblowers “who voluntarily provided original information to the Commission that led to the successful enforcement of the covered judicial or administrative action, or related action.” According to the D.C. Circuit, this language means that a whistleblower’s submission to the SEC must itself have led to successful enforcement; it is not enough for the whistleblower to make a disclosure to a third party which leads to enforcement and submit the same information to the Commission.

Judge Karen LeCraft Henderson dissented in the case, arguing that the majority had conflated two distinct statutory requirements. “[A] whistleblower satisfies the causation requirement when his ‘original information’ is what ‘led to the successful enforcement of the covered . . . action’” and he submits that information to the Commission, she argued. In her view, disqualifying whistleblowers who meet both of these criteria in separate instances is contrary to the text of the Dodd-Frank Act.

National Whistleblower Center (NWC) chairman and Kohn, Kohn, & Colapinto founding partner Stephen M. Kohn agreed with Henderson’s interpretation. He pointed to one of the majority’s first sentences – “To qualify for an award, a whistleblower must provide original information to the SEC, and that information must be instrumental in a successful enforcement action” – as evidence that Doe should have qualified for an award.

“The majority’s own description of Dodd-Frank’s award requirements favors the whistleblower denied in this case,” Kohn said. “John Doe provided original information to the SEC which was instrumental in enforcement. That’s what Dodd-Frank requires.”

“Media whistleblowers are some of the most important whistleblowers we have,” Kohn continued. “They have led to massive government recoveries and pushed investigators to focus on crucial instances of fraud. The D.C. Circuit’s decision will disincentivize whistleblowers from going to the media, which in turn will actively harm investigatory efforts.”

In March, NWC filed an amicus brief in a similar case currently awaiting oral argument in the Eleventh Circuit. NWC argued that the plain meaning and legislative history of Dodd-Frank both supported media whistleblowers being eligible for awards so long as they subsequently submitted their media tips to the SEC. It remains to be seen whether the Eleventh Circuit will agree with the D.C. Circuit or adopt Henderson’s reading of the statute.

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The AIWPA fills a crucial gap in current whistleblower regulations, but it does not reinvent the wheel. Previous legislation protected whistleblowers in other industries, such as food, transportation, and medicine, that are similar to those in the bill proposed to protect AI whistleblowers.

The AI Whistleblower Protection Act includes the same basic principles as current laws: Regulation, Disclosure, and Relief.

For example, the proposed bill prohibits employer retaliation against employees. It states, “No employer may, directly or indirectly, discharge, demote, suspend, threaten, blacklist, harass, or in any other manner discriminate against a covered individual.”

Similarly, the Food Safety Modernization Act of 2010 (21 U.S. Code § 399d) states, “No entity engaged in the manufacture, processing, packing, transporting, distribution, reception, holding, or importation of food may discharge an employee or otherwise discriminate against an employee with respect to compensation, terms, conditions, or privileges of employment.” Both share the same basic premise: no employer in the bill’s specific industry is allowed to discriminate against employees who report company violations.

Likewise, the AI Whistleblower Protection Act has similar protections in Disclosure rules. It states that employees may submit their complaint to the Secretary of Labor, and if necessary, bring their employer to district court for a jury trial. Similarly, the whistleblower protections under the Surface Transportation Assistance Act (STAA) (49 U.S. Code § 31105) hold that employees may file a complaint with the Secretary of Labor.

Last, the AI Whistleblower Protection Act awards successful whistleblowers reinstatement of previously lost employment, double backpay (including interest), and compensatory damages. In comparison, The Internal Revenue Code (26 U.S. Code § 7623) lists compensatory damages including reinstatement of the same seniority status the employee would have held, the sum of 200 percent back pay (equaling to two times the amount) with interest, and compensation for any special damages such as litigation costs, expert witness fees, and attorney fees.

The AI Whistleblower Protection Act includes tried-and-true principles and formats that work. Advocates, like whistleblower attorney Stephen Kohn, warn that current whistleblower protection laws do not protect employees within the AI industry, making the AI Whistleblower Protection Act an important addition.

The post A New Sense of Urgency in The World of Technology: What the AI Whistleblower Protection Act Protects appeared first on Whistleblower Network News.

According to a Justice Department press release, WHIP will pay awards to whistleblowers who submit qualifying tips alleging fraud against certain government agencies or health care providers. The Justice Department stated that awards will range from $10,000 to $30,000. President Trump instead said in a press conference that the program would grant a 1% commission on the amount of fraud uncovered, although it is unclear how such percentages would be calculated given that the program is designed to provide awards before judicial investigations take place.

Regardless of which award calculation is correct, WHIP awards will be much smaller than awards already offered for whistleblowers who report fraud against the government under the False Claims Act. That law, which allows whistleblowers to file qui tam lawsuits on the government’s behalf, led to over $6.8 billion in government recoveries in the 2025 fiscal year – over $5.3 billion of which came from whistleblower tips.

Whistleblowers received over $330 million in awards – granted as percentages of successful recoveries – under the False Claims Act in fiscal year 2025 alone. WHIP, with a total budget of $25 million, will likely have a much smaller impact.

“There already exists a whistleblower law that pays 15-30% for theft of taxpayer money,” said leading whistleblower attorney David Colapinto in a tweet responding to the announcement, describing the False Claims Act program as simply “better than 1%.”

WHIP’s award determination mechanism is also unclear. The Justice Department’s FAQ website states that awards will be granted based on the Department’s sole discretion, but President Trump suggested in his press conference that he would make award determinations individually. Either structure would provide much less certainty to whistleblowers than the False Claims Act, under which awards are mandatory if a whistleblower is found to meet the applicable statutory requirements. WHIP’s confidentiality protections are also entirely discretionary, whereas False Claims Act whistleblowers can file their lawsuits under seal and thus receive judicial security.

Finally, WHIP’s basic eligibility criteria site states that only “individuals who did not actively participate in the fraud” can qualify for awards, although its FAQ site states that those with a “limited” and “minimal” role in fraud may qualify for awards at the Justice Department’s discretion. The False Claims Act only bars individuals convicted of criminal conduct in relation to the fraud from receiving awards, although an award percentage can be reduced based on culpability. This policy is based on the well-known whistleblower principle “it takes a rogue to catch a rogue,” which recognizes that individuals with some involvement in fraud are often the ones who know the most about it.

“In order for whistleblowers to come forward, they need to know what to expect,” Colapinto said. “Without that clarity, whistleblowers can have no confidence that their information will be properly utilized, or that they will receive proper credit for assisting the U.S. in such sensitive matters.

The post New Trump Administration Whistleblower Program Offers Small, Non-Mandatory Awards appeared first on Whistleblower Network News.

The CFTC found that each of the four whistleblowers “provided significant information” which led to successful enforcement. However, the CFTC’s final determination reduced the overall award amount based on two regulations which require the Commission to analyze whether an award amount “enhances the Commission’s ability to enforce the Commodity Exchange Act, protect customers, and encourage the submission of high quality information from whistleblowers” or creates “potential adverse incentives.”

The CFTC issued a smaller award because it was concerned that “excessive monetary incentives may lead to misreporting and cause investigative waste.” Pointing to a significant increase in CFTC award applications between 2021 and 2023 after the Commission granted an award that reached nine figures, and a few examples of obviously nonmeritorious applications, the Commission held that “oversized awards encourage frivolous submissions, drain Commission resources, and impair the Commission’s ability to effectively enforce the CEA and protect customers.”

Notably, the Commission did not provide evidence that the increase in award applications between 2021 and 2023 increased the proportion of frivolous applications being submitted.

“At the outset, the Commission’s argument misrepresents the data,” said leading whistleblower attorney and National Whistleblower Center chairman Stephen M. Kohn. “Evidence shows that while publicity from large awards leads to some meritless applications, this effect is far outweighed by the useful information the government receives. Without demonstrating that a higher percent of those applications are frivolous, which the CFTC does not, you can’t in good faith call this an adverse incentive.”

Kohn pointed to several academic articles demonstrating that the “possibility of increased credible tips” incentivized by granting whistleblower awards “outweighs the potential burden.” A 2024 report from the United Kingdom’s most prestigious think tank, for example, held that “reward programmes are effective at increasing not only the quantity, but also the quality of information provided to regulators.” The United Kingdom has historically been averse to award incentives for whistleblowers.

Kohn also noted that in 2022, the Securities and Exchange Commission (SEC) – which runs a similarly structured whistleblower program – passed a new regulation forbidding the Commission from considering the dollar amount of an award for the purpose of decreasing the award, finding that “this amendment will help strengthen the whistleblower program by encouraging high-quality tips from insiders and others who have original information relating to potential securities law violations.” In contrast to the CFTC’s reasoning, the SEC found that reducing awards because they were too large would “discourage whistleblowers from coming forward.”

“The SEC has it right,” said Kohn. “Large awards are critical to incentivize whistleblower disclosures, which lead to huge government recoveries. The CFTC’s logic radically misunderstands how whistleblower award programs work.”

The post Recent CFTC Award Determination Sets Dangerous Precedent, Advocates Warn appeared first on Whistleblower Network News.

“[T]he pattern is clear,” McNulty said. “Where incentives exist, whistleblowers come forward.” He pointed to his prior experience as the UK’s police lead for informants – noting that “the principle of having an insider is the same” – and argued that collaboration with whistleblowers allows the government to conduct investigations more efficiently, detect more crime, and make the litigation process more efficient by increasing corporate self-referrals and guilty pleas.

The UK’s general attitude towards whistleblower incentives was once highly negative; as McNulty put it, “Paying for information was once seen as ‘un-British.’” But this attitude has been shifting in recent years, as exemplified by a 2024 report by the U.K.’s most prestigious think tank which strongly supported whistleblower reward programs.

UK hostility towards rewards may now be a thing of the past. In his op-ed, McNulty announced that recent polling data shows “70 per cent of the public now support financially rewarding whistleblowers who expose serious economic crime.”

“It’s very promising that the SFO is recognizing the unparalleled success and promise of whistleblower reward laws in fighting crime, and the strong support these laws have from the public,” said Benjamin Calitri, associate attorney at leading whistleblower law firm Kohn, Kohn & Colapinto. Calitri has written articles for publications like Oxford Business Law Blog and The Banker on the need for U.K. whistleblower rewards, and has spoken at several U.K. whistleblower forums on the same topic.

The U.K. government is currently consulting on the implementation of a whistleblower incentive program, which McNulty described as “a significant step towards an outcome that would transform how complex fraud is tackled in the UK in the same way that proceeds of crime legislation enabled law enforcement to turn the tables on criminals in the early 2000s.”

“Serious fraud, bribery, and corruption are caught from the inside,” McNulty said. “Incentivizing whistleblowers works.”

The post Interim Head of UK Serious Fraud Office Voices Support for Whistleblower Rewards in Op-Ed appeared first on Whistleblower Network News.

Before leaving Facebook, Haugen copied thousands of pages from confidential documents and shared them with Congress, the Securities and Exchange Commission, and The Wall Street Journal, which published a report called “The Facebook Files.” Despite the risk of speaking out against a company with more resources and reach, Haugen testified because she recognized the harm Facebook was causing the public as it prioritized profits.

Haugen claimed, “As long as Facebook is operating in the dark, it is accountable to no one. And it will continue to make choices that go against the common good. Our common good.”

She also told Congress, “I believe what I did was right and necessary for the common good, but I know Facebook has infinite resources, which it could use to destroy me.”

Although Haugen was protected by anti-retaliation provisions under the 2010 Dodd-Frank Act, she feared her career would be ruined by testifying publicly, given that Facebook had far more resources than she did. Despite these fears, Haugen was commended internationally and traveled to Europe to help strengthen regulations. Recognition like this highlights the contributions of people who expose potential wrongdoing and bring it to light. Beyond honoring efforts, whistleblower awards raise awareness and incentivize others to speak out. Following her testimony, eight new whistleblower complaints were filed with the SEC.

Five years later, Frances Haugen’s story is being immortalized in the 2026 film, The Social Reckoning. The film follows Haugen as a young Facebook engineer who sought assistance from Jeff Horowitz, a Wall Street Journal reporter, to blow the whistle on Facebook’s classified secrets. Stories like hers reinforce the importance of whistleblower protections across industries.

“The Haugen story reemphasized the importance of enacting regulations to protect social media whistleblowers,” said Stephen M. Kohn, Chairman of the National Whistleblower Center. “We urge federal regulators, such as the SEC, to insist that securities and safety laws be meticulously followed in this otherwise unregulated and dangerous industry.”

The post New Film on Frances Haugen Underscores the Importance of Protecting Social Media Whistleblowers appeared first on Whistleblower Network News.

The DOJ expressed concerns about frivolous qui tam actions and regulating the use of government resources. In their recent press release regarding the FCA revisions, Associate Deputy Attorney General Paul Perkins claims that, “These revisions will help ensure the Department uses its enforcement authority fairly and effectively—holding fraudsters accountable for violations of binding legal or contractual obligations while seeking dismissal of meritless qui tam actions that waste taxpayer resources and impose unjustified burdens on businesses.”

The DOJ has maintained that it “will continue to exercise this authority judiciously, with an emphasis on seeking dismissal of qui tam actions that lack legal or factual merit and focusing Department resources on matters that advance the interests of the United States.”

The revisions and Perkins’ statements largely point to the government’s desire to cut government spending on qui tamactions it deems dismissible or meritless. Whistleblower advocates have expressed concern that these revisions could discourage people from coming forward to report fraud.

Whistleblower attorney Stephen M. Kohn expressed concern that the revisions may increase dismissals of valid qui tam actions and reduce representation for true whistleblowers. Kohn believes this may discourage whistleblowers from coming forward to report government fraud.

The post How Changes to the DOJ Justice Manual Could Impact FCA Whistleblowers appeared first on Whistleblower Network News.

The event, held on October 21st at the Vienna International Center in Vienna, Austria, will feature leading experts on whistleblower laws who will discuss how to maximize detection and deterrence of transnational financial crime, including money laundering and illegal offshore banking.

The overarching U.N. Conference on Transnational Crime will be taking place from October 19-23. UNTOC is the main international legal instrument in the fight against transnational organized crime. The Conference of the Parties was established to improve member states’ ability to combat transnational organized crime and to promote and review the implementation of the Convention. 

NWC’s discussion will center on how anti-corruption advocates can promote formal cooperation, mitigate asymmetric enforcement capacity, and successfully incentivize whistleblowers to report transnational criminal activity. In short, the event will provide educational training on highly effective transnational whistleblower laws. 

The panel will be chaired by Stephen Kohn, Chair of the National Whistleblower Center, who drafted the AML Enhancement Act and represented the whistleblower in perhaps the largest money laundering case in history, the $230 billion Danske Bank scandal. Other speakers include Eliza Lockhart, a Senior Research Fellow with the Royal United Services Institute, whose research informed U.K. policy discussions on whistleblower rewards programs, and Jeana Lee, Program Manager at the National Whistleblower Center.

“Transnational whistleblower laws are often unheard of across various parts of the globe. So we are excited to utilize the international platform in Vienna to educate countries, big or small, on how they can take advantage of effective legal tools to combat transnational crime,” said Lee, who will be moderating the side event. 

The post NWC to Host Side-Event at United Nations Transnational Crime Conference appeared first on Whistleblower Network News.

HMRC’s Strengthened Reward Scheme was launched in November 2025 to incentivize and promote civil reporting of tax evasion and fraud in the UK and beyond. It is modeled after successful US-style rewards programs that emphasize large rewards and confidentiality protections for whistleblowers. 

From 2007 to 2020, the IRS Whistleblower Rewards Program led to the collection of over $5.9 billion and gave out over $1 billion in awards. The program revealed how incentives for whistleblowers can have a powerful detection and deterrence effect on financial crime. HMRC’s Strengthened Reward Scheme seeks to emulate this success with the help of the IRS.

In the IRS news release, IRS Chief Executive Officer Frank J. Bisignano said, “ By working together, the two tax authorities encourage robust tax enforcement on both sides of the Atlantic and will have a far-reaching global impact in the fight against international financial fraud.” 

This partnership between HMRC and the IRS aims to reward whistleblowers who vitally contribute to the government by assisting agencies in identifying fraudsters who threaten global economic security and dismiss tax compliance. 

Both agencies encourage individuals to speak out against financial violations or gather more information by utilizing the IRS Whistleblower Office or IRS.gov/SubmitATip, and in the UK the Reporting Serious Tax Avoidance or Evasion. 

The post HMRC’s Partnership With the IRS: What It Means For Whistleblowers appeared first on Whistleblower Network News.

The survey reveals that 68% of registered voters favor federal employee whistleblowers having the same access to court and jury trials that government employees and contractors have to defend against free-speech retaliation, while only 5% oppose this. The survey also shows that 86% of registered voters believe passing stronger laws that protect whistleblowers should be a priority for Congress, a statistic that has gone up from 81% since 2020. Lastly, 64% of voters claim to be more likely to vote for a Congressional candidate who supports strengthening laws that protect employees who report fraud, up from 44% since 2020.

“These results demonstrate beyond a reasonable doubt that providing effective protections for whistleblowers are of urgent concern to the overwhelming majority of the American public,” said Stephen Kohn, Founder and Chairman of the Board at the National Whistleblower Center. “This is an urgent message to hold corporations and the government accountable for corruption.”

Support for whistleblower protections may also have implications for the upcoming 2026 midterm elections, as voters continue to consider candidates. The poll’s results play a vital role in shaping candidates’ understanding of public opinion on whistleblowing. As major issues such as rising corruption in federal government and the dangerous impacts of Artificial Intelligence are on American’s minds, politicians’ support for whistleblowers will be critical to tackling these challenges.

“These findings confirmed an overwhelming mandate for Congress to rebuild America’s whistleblower laws, which have been ravaged for federal employees and workers around the country,” said Maya Efrati, Director of Legislation and Congressional Affairs at Government Accountability Project. “The public knows that whistleblowers are America’s best defense against government fraud, waste, and abuse. It’s time for the legislators to listen.”

The post New Poll Reveals Overwhelming Public Support for Whistleblowers appeared first on Whistleblower Network News.