Managing Risks and Rewards: How Incentives Can Change the Whistleblower Landscape

The Rt Hon. the Baroness Kramer (Susan Veronica Kramer) is a current member of the House of Lords and one of Parliament’s leading voices for whistleblower reform. A Liberal Democrat peer, she is a former Minister of State for Transport and now serves as the party’s Lords spokesperson for Treasury and the economy. She has been a persistent advocate for stronger protections and incentives, championing an Office of the Whistleblower Bill in the House of Lords and, more recently, helping secure a landmark amendment to the Employment Rights Bill that introduces a duty on larger employers to investigate whistleblowing concerns. She has openly pointed to the success of US-style reward programs, noting in the Lords that roughly a quarter of the US CFTC’s cases have stemmed from tips by UK whistleblowers — making her a fitting voice for this discussion on rewards and incentives.

Georgina Halford-Hall is the Chief Executive of WhistleblowersUK and serves as Director of Strategy & Policy for the All-Party Parliamentary Group for Whistleblowing. She came to the cause firsthand: she founded WhistleblowersUK after blowing the whistle on financial irregularities and poor practice at a charity, discovering how isolated and unsupported whistleblowers often are once they speak up.

Benjamin is an experienced associate attorney at Kohn, Kohn & Colapinto, representing whistleblowers in retaliation and award cases. Ben has filed award claims for whistleblowers under the Dodd-Frank Act with the Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC).

Similarly, he has filed tax evasion claims with the Internal Revenue Service (IRS), money laundering/sanctions violations cases with the Financial Crimes Enforcement Network (FinCEN) and False Claims Act cases in federal court. To date, whistleblowers Ben has represented have worked with the United States in recovering over $5 billion in sanctions.

Ben also is active in representing whistleblowers who have suffered retaliation, including cases filed under the Sarbanes-Oxley Act, and arbitration cases under FINRA’s Alternative Dispute Resolution. Ben has developed expertise in combating illegal non-disclosure agreements and representing clients in cryptocurrency claims.

An accomplished speaker, Ben has been a featured presenter at the Association of Certified Fraud Examiners’ White Collar Crime Conference, Anti-Fraud Coalition’s Annual Conference, and Whistleblower UK’s Whistleblower Awareness Week held in London, among others. He is also a member of the Whistleblower UK’s attorneys committee.

Ben has also published extensive articles in publications such as the Financial Times, Oxford Business Law Blog, Columbia Law School Blue Sky Blog, New York University School of Law Program on Corporate Compliance and Enforcement, Law360, and National Law Review.

HM Revenue & Customs is the United Kingdom’s tax, payments, and customs authority, responsible for collecting the revenue that funds the country’s public services and for tackling tax avoidance and evasion. HMRC sits at the center of this conversation following a landmark policy shift: its new Strengthened Reward Scheme, confirmed in the Autumn Budget 2025 and modelled on the US IRS Whistleblower Program. Under the scheme, whistleblowers whose information leads to the recovery of at least £1.5 million in tax can qualify for a reward of between 15% and 30% of the amount collected, with the program targeting high-value evasion involving offshore schemes, wealthy individuals, and large corporations. The scheme marks a clear departure from the UK’s traditional reluctance to financially reward whistleblowers, making HMRC’s perspective central to any discussion of how incentives can reshape the whistleblower landscape.

HM Revenue & Customs is the United Kingdom’s tax, payments, and customs authority, responsible for collecting the revenue that funds the country’s public services and for tackling tax avoidance and evasion. HMRC sits at the center of this conversation following a landmark policy shift: its new Strengthened Reward Scheme, confirmed in the Autumn Budget 2025 and modelled on the US IRS Whistleblower Program. Under the scheme, whistleblowers whose information leads to the recovery of at least £1.5 million in tax can qualify for a reward of between 15% and 30% of the amount collected, with the program targeting high-value evasion involving offshore schemes, wealthy individuals, and large corporations. The scheme marks a clear departure from the UK’s traditional reluctance to financially reward whistleblowers, making HMRC’s perspective central to any discussion of how incentives can reshape the whistleblower landscape.