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At the eleventh session of the Conference of the State Parties (CoSP 11) to the United Nations Convention Against Corruption (UNCAC), National Whistleblower Center International Liaison Kate Reeves delivered a pointed message: the global approach to whistleblower protection is fundamentally insufficient.
While many states have committed to whistleblower protection and passed new legislation since 2020, Reeves argued that the conversation remains stuck in a retroactive framework—one that only helps whistleblowers after they’ve already suffered.
The Problem with Current Frameworks
When “whistleblower protection” is discussed at international forums, it typically refers to damages for harm and criminalization of retaliation. These measures are important, but they require whistleblowers to suffer first—losing jobs, enduring mental health crises, facing stalking and intimidation—before any remedy becomes available.
“The mark of success at the end of that arduous process is simply survival,” Reeves said. Whistleblowers emerge from years-long legal battles “lucky if they have been compensated for lost income and attorney’s fees.”
Meanwhile, the wrongdoing they reported often goes uninvestigated. The company faces no trial—but the whistleblower does.
A Better Approach: The Three I’s
Reeves outlined three elements that transform whistleblowing from a labor dispute into an effective anti-corruption strategy:
Incentivization: Financial rewards for whistleblowers whose tips lead to successful enforcement actions.
Identity Protections: Robust anonymity provisions that allow whistleblowers to report without exposing themselves to retaliation.
Investigations That Lead to Enforcement: Systems designed to investigate the wrongdoing—not the whistleblower.
Proof It Works
U.S. programs like the Dodd-Frank Act and the Anti-Money Laundering Whistleblower Protection Act demonstrate that this approach delivers results. Since these programs were introduced, whistleblower reports have skyrocketed, leading to the discovery of billions in transnational corruption that would never have been uncovered otherwise.
The system works because it flips the risk dynamic: whistleblowers can remain anonymous, the investigation focuses on their claims rather than on them personally, and there’s potential for financial reward. The result? Whistleblowers from jurisdictions around the world have flooded to the U.S. to report corruption.
A Call for Change
To fulfill the mandates of UNCAC—including Article 1’s requirement that states promote measures to more effectively combat corruption, and Articles 32 and 33 requiring whistleblower protections—Reeves urged state parties to mobilize whistleblowers as an offensive strategy against corruption, not merely defend them after harm has occurred.
“As long as legislation and nations worldwide continue to treat whistleblowers as a labor dispute issue, and not an anti-corruption strategy,” Reeves concluded, “whistleblowers will continue to suffer and states will continue to underutilize their most effective anti-corruption tool: informed insiders.” The National Whistleblower Center urges that this perspective be formally recognized in future CoSP proceedings and welcomes collaboration with states interested in championing this cause.
Joseph Orr
Joseph is an author at IWPA and writes about anti-corruption.
