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Friday, April 17, 2026

6 Key Takeaways | Whistleblower Programs: How the U.S. Government Seeks to Create a Speak-Up Culture & Parts of the World Want One Too - Lexology

  1. All are welcome. Whistleblowers do not need to be U.S. citizens or residents to benefit from the statutes or reward programs
  2. The Securities and Exchange Commission has the most successful program. The SEC has reached over U.S. $1 billion in payouts to whistleblowers.

• In 2021, the SEC handled over 12,200 tips.

• Up 76% from 2020 and a more than 300% increase since the beginning of the program.

• Awards of about $564 million to 108 individuals in fiscal year 2021 (more than the combined total for fiscal years 2011 through 2020).

• The SEC received tips from individuals in 99 foreign countries and from every state in the U.S., including the District of Columbia.

• Approximately 20% of the meritorious claimants in 2021 were based outside of the U.S.

  1. A reward program incentivizes even those who may be culpable. One notable September 24, 2021 SEC high-profile award to a whistleblower may set a precedent for other government whistleblower programs.

• The SEC awarded a $36 million bounty to a single whistleblower claimant, who provided information related to a SEC and another federal agency’s actions.

• The whistleblower delayed reporting for over five years (which is also the statute of limitations for most federal crimes).

• The whistleblower alleged misconduct by a financial institution and personnel from a “foreign government entity,” while being culpable for the underlying misconduct.

  1. The EU Directive on Whistleblower Protection provides broad protections abroad.

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