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.
Contacts
Insights
Client Alert | 3 min read | 03.12.26
DOJ Releases First-Ever Department-Wide Corporate Enforcement and Voluntary Self-Disclosure Policy
On March 10, 2026, the Department of Justice released the first-ever Department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy (the “Department-wide CEP” or “Policy”), which applies to all non-antitrust corporate criminal cases across the Department. The new policy has been anticipated since December 2025, when Deputy Attorney General Todd Blanche announced the Department’s plans to release a new, single corporate enforcement policy for all criminal matters. According to the Department, the new policy is designed to “help ensure consistency across the Department” and “transparently describe the Department’s policies and decisionmaking.”
Client Alert | 2 min read | 03.11.26
Client Alert | 3 min read | 03.11.26
Civil Litigation as a First-Response Strategy: The UK Government's Fraud Strategy 2026–2029
Client Alert | 5 min read | 03.11.26
CJEU Sets the Bar Low for Evidence Disclosure in Competition Damages Litigation

