The United States government has four primary whistleblower statutes and reward programs:
All of these whistleblower programs are quite democratic. These programs permit non-American citizens to file a complaint in a court of law (in the case of the FCA) or submit an agency tip (in the case of the SEC, CFTC, and IRS whistleblower programs). Non-citizens, whether they reside in the U.S. or abroad, are generally treated on equal footing with U.S. citizens under the whistleblower statutes and reward programs. Eligible whistleblowers can seek, and have received, sizeable rewards under these whistleblower programs regardless of their citizenship.
Available data shows that foreign citizens are an integral part of the whistleblower system. And this is particularly true for SEC whistleblowers. In fiscal year 2021 alone, the SEC received over 1,300 tips from individuals in 99 foreign countries. Of interest, the greatest number of foreign tips came from Australia, Brazil, Canada, China, Colombia, Germany, India, Russia, Singapore, Turkey, and the United Kingdom.
The critical importance of foreign whistleblowers to SEC enforcement should come as no surprise. Many foreign companies list shares on American stock exchanges, thousands of American...
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