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A focus on multinationals: Whistleblower incentives on the international stage

Client Alert | 1 min read | 08.05.21

2020 was one of the first years in memory when many multinationals saw a reduction in the number of internal whistleblower complaints, and a sharp increase in the number of external whistleblower complaints. In this environment, several countries around the world are finding ways to incentivize external whistleblower complaints, including—following the United States’ lead—providing bounties tied to money that governments recover as a result of those complaints. In this article by Crowell & Moring Partner Preston Pugh and Incoming 2022 First Year Associate Danielle Alvarez, part one of a two-part series, we discuss the development of these laws and the specific types of complaints whistleblower bounty laws cover. In part two, we will provide recommendations on how multinationals can best prepare for these developments.

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Client Alert | 7 min read | 10.27.26

New Developments in DOJ Whistleblower Policies and HHS Disclosures: Key Takeaways for General Counsel, Chief Compliance Officers, and Boards

On October 20, 2026, the U.S. Department of Justice’s (DOJ) National Fraud Enforcement Division announced a new whistleblower rewards initiative, the Fraud Whistleblower Incentive Program (WHIP). Assistant Attorney General Colin M. McDonald issued a directive earlier this month directing Division leadership to design and implement policies and programs that incentivize whistleblowers to bring forward credible information pertaining to fraud. The new WHIP incentive pays awards of $10,000 to $30,000 for qualifying tips at or around the time criminal charges are filed or unsealed, rather than years later at case resolution....