Introduction: Why This Matters
Witnessing fraud or corruption can feel lonely and frightening. You may have seen something at your bank, your company, or a government contract that you know is wrong — and you may believe there is nothing you can do about it, especially if you live outside the United States. You are not powerless. Even from another country, you may be able to use powerful U.S. laws to report wrongdoing safely, confidentially, and — in many cases — in exchange for a financial reward.
This guide is written for people who are just beginning to learn about whistleblowing. You do not need any legal background to understand it. We will explain, in simple terms, what the major U.S. whistleblower programs are, who can use them, what kinds of wrongdoing they cover, and how to take your first steps. Throughout, we link to official government sources and to our more detailed guides so you can go deeper when you are ready.
You can use U.S. law to report fraud and corruption
The United States has built the most effective whistleblower reward laws in the world. Several U.S. agencies — including the Securities and Exchange Commission (SEC), the Commodity Futures Trading Commission (CFTC), the Internal Revenue Service (IRS), and the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) — operate programs that pay people who report certain violations of U.S. law.
What surprises many people is how far these laws reach. U.S. law can apply to conduct that happens overseas, as long as it touches the U.S. financial system, U.S. markets, U.S. taxpayers, or a company connected to the United States. A bribe paid in one country, money laundered through a bank in another, or a foreign company that misleads U.S. investors can all fall under U.S. jurisdiction. That is why these programs are open to whistleblowers around the world.
Awards are available to people with good information
These are not symbolic rewards. When a whistleblower provides original, high-quality information that leads to a successful enforcement action, the law can require the government to pay them a percentage of the money it collects. Under the SEC and CFTC programs, that share is between 10% and 30% of the money collected when sanctions exceed $1 million. Under the IRS program, awards range from 15% to 30%.
The numbers are real and substantial. The SEC’s whistleblower program has paid roughly $2 billion to about 400 whistleblowers since 2011, including a single award of $279 million. The CFTC has paid more than $430 million tied to over $3.7 billion in sanctions. The IRS has collected over $7.5 billion with help from whistleblowers and paid them more than $1.3 billion. And under the False Claims Act, whistleblowers helped the government recover a record $6.8 billion in a single year. Awards are never guaranteed, and they depend on the strength of your information — but for the right case, they can be life-changing.
International whistleblowers bring some of the most important cases
Some of the most consequential whistleblower cases in history came from people outside the United States. Bradley Birkenfeld, an American banker working at UBS in Switzerland, exposed a scheme that helped thousands of U.S. taxpayers hide money in secret Swiss accounts. His disclosures forced UBS to reveal more than 4,450 account holders and pay a $780 million fine, and he received a $104 million award from the IRS — represented by our firm. Howard Wilkinson, a British manager at Danske Bank’s Estonian branch, uncovered roughly $230 billion in suspicious Russian money flowing through the bank and into the U.S. financial system — what many experts call the largest money laundering scandal in history. He, too, is our client.
These are not isolated stories. The SEC regularly receives tips from dozens of countries, and the CFTC has reported tips from more than 60 nations in a single year. Insiders who live and work where the misconduct happens often hold exactly the evidence U.S. agencies need.
Most countries still lack strong whistleblower reward laws — but that is changing
Outside the United States, very few countries reward whistleblowers, and many offer little protection from retaliation. This is one of the main reasons U.S. programs matter so much to people abroad: often, they are the only realistic path to both protection and a reward. That picture is slowly improving. The United Kingdom, for example, has announced a new HMRC reward scheme modeled on the U.S. approach. But for now, the U.S. programs remain the strongest and most proven tools available to international whistleblowers.
The U.S. programs available to international whistleblowers
This guide covers the major programs you can use, whether or not you are a U.S. citizen and whether or not you live in the United States:
- The FinCEN Anti-Money Laundering & Sanctions Program — for reporting money laundering, sanctions evasion, and Bank Secrecy Act violations.
- The Foreign Corrupt Practices Act (FCPA) — for reporting foreign bribery, reported through the SEC or CFTC programs.
- The SEC and CFTC Whistleblower Programs — for reporting securities fraud, commodities and derivatives fraud, and market manipulation.
- The IRS Whistleblower Program — for reporting tax fraud and evasion involving U.S. taxpayers.
- The False Claims Act (Qui Tam) — for reporting fraud against the U.S. government, such as contract, grant, or healthcare fraud.
In the next section, we explain each program in plain language: what it covers, who can use it, how to qualify, real examples, and where to report. If at any point you feel ready to talk to someone, International Whistleblower Advocates offers a free and confidential consultation.
The U.S. Whistleblower Programs
Below, we walk through each major program one at a time. For each, we explain what it covers, who can use it, how to qualify, and what real cases look like — and we link to our detailed guide so you can learn more when you’re ready.
We begin with the program that is often the most relevant for international whistleblowers today: FinCEN.
1. The FinCEN Anti-Money Laundering & Sanctions Whistleblower Program
Why this program matters right now
If you have information about money laundering or sanctions evasion moving through the global financial system, this is likely your program — and there is a reason to act sooner rather than later. The FinCEN program is new. Congress created it through the Anti-Money Laundering Act of 2020 and strengthened it with the Anti-Money Laundering Whistleblower Improvement Act of 2022. In March 2026, FinCEN proposed the rules that will govern how awards are paid.
Here is the key point, stated plainly: FinCEN is already accepting tips, but it has not yet paid any awards, because the award rules are still being finalized. That means the field is wide open. Whistleblowers who come forward early — while the program is still young — may be among the first in line when the government begins paying awards. We’ll be precise throughout this guide: the reward percentages below come from the law and the proposed rule, not from a track record of payments that exists yet.
Benefits and features
Under the program, a whistleblower who voluntarily provides original information that leads to a successful enforcement action with sanctions over $1 million may be eligible to receive between 10% and 30% of the money the government collects. On a large bank penalty, that share can be enormous. The law also protects you: it forbids employers from firing, demoting, or otherwise retaliating against whistleblowers, and it requires the government to protect your identity.
What to report
FinCEN, a bureau of the U.S. Treasury Department, is the United States’ lead agency against money laundering and financial crime. This program covers violations of the Bank Secrecy Act (the U.S. anti-money laundering law) and of major U.S. sanctions laws, including the International Emergency Economic Powers Act, the Trading With the Enemy Act, and the Foreign Narcotics Kingpin Designation Act. In practice, that includes things like:
- A bank ignoring or hiding suspicious transactions instead of reporting them
- Helping sanctioned individuals, companies, or countries move money through the financial system
- Shell companies used to disguise the origin of illicit funds
- A financial institution failing to verify who its customers really are (“Know Your Customer” failures)
- Moving the proceeds of crime — drug trafficking, corruption, fraud — into legitimate accounts
A real example
The power of this kind of reporting is best shown by our client Howard Wilkinson. As a manager at Danske Bank’s Estonian branch, he uncovered roughly $230 billion in suspicious payments — much of it Russian money — flowing through the bank and into the U.S. financial system. It is widely described as the largest money laundering scandal in history. His disclosures reshaped how the world thinks about cross-border money laundering. Cases exactly like his — an insider at a non-U.S. bank, watching dirty money touch the U.S. system — are what the FinCEN program is built for.
Who can qualify
You do not need to be a U.S. citizen, and you do not need to live in the United States. The program is open to any individual with original information. That includes bank tellers, compliance officers, loan officers, auditors, and managers, as well as former employees, contractors, and customers who witnessed wrongdoing. Importantly, compliance professionals are allowed to report — the people whose jobs give them the clearest view of violations are not shut out.
How to qualify
To be eligible for an award, your information generally must be:
- Original — drawn from your own knowledge or analysis, not already known to the government or sourced from public records
- Voluntary — provided on your own initiative, not in response to a government request or subpoena
- Specific and credible — concrete enough that investigators can act on it
- Significant — leading to an enforcement action with sanctions above $1 million
Can you report anonymously?
Yes — but with one condition. You may submit your tip anonymously, as long as you are represented by an attorney. Your lawyer files on your behalf, acting as a shield between you and both your employer and the government. You will need to confirm your identity to the government before any award is paid, but you can remain anonymous throughout the reporting and investigation stages.
Do you need an attorney, and how do they help?
For an anonymous filing, an attorney is required. Even if you were not filing anonymously, a skilled whistleblower lawyer dramatically improves your position: they help you preserve evidence lawfully, prepare a submission that investigators take seriously, protect you from retaliation, and argue for the highest possible award percentage. Mistakes early on — sharing information publicly, taking documents improperly, or filing without understanding the rules — can weaken or destroy an otherwise strong case.
Where to report and learn more
You can read our full, step-by-step guide here: FinCEN Whistleblowing Guide: AML, BSA and Sanctions Violations. For common questions, see our FinCEN Whistleblower Program FAQ. If you think you may have a case, you can request a free and confidential consultation.
2. The Foreign Corrupt Practices Act (FCPA): Reporting Foreign Bribery
A different kind of program: a law you report through the SEC or CFTC
The FCPA is slightly different from the other programs in this guide, and it’s worth understanding why. The FCPA is not its own whistleblower office with its own reward fund. It is a U.S. anti-bribery law — and when you report a violation of it, you do so through the SEC Whistleblower Program (and, in some cases, the CFTC program). The reward comes from those programs. So when people talk about an “FCPA whistleblower,” they usually mean someone who reported foreign bribery to the SEC and qualified for an SEC award.
This matters for you because it means foreign bribery is one of the most powerful things an international whistleblower can report — and the same generous reward rules apply: 10% to 30% of the money collected when sanctions exceed $1 million.
What the FCPA covers
Passed in 1977, the FCPA makes it illegal for companies connected to the United States to bribe foreign government officials to win or keep business. It reaches much further than many people expect.
It applies to:
- U.S. companies and citizens anywhere in the world
- Foreign companies whose shares trade on a U.S. exchange, or that are otherwise required to file with the SEC
- Anyone who takes an action in furtherance of a corrupt payment while in U.S. territory
It also has an “accounting provisions” component. Companies listed in the U.S. must keep accurate books and maintain real financial controls. Hiding bribes through falsified records is itself a violation — and these accounting cases are a major focus of SEC enforcement.
What to report
Common FCPA violations include:
- Paying cash, gifts, travel, or other things of value to a foreign official to win a contract
- Funneling bribes through “agents,” consultants, distributors, or joint-venture partners
- Maintaining slush funds or off-the-books accounts to pay officials
- Falsifying company records to disguise improper payments
The CFTC connection
Here is where the interplay you may not expect comes in. Foreign bribery doesn’t only distort securities markets — it can distort commodities and derivatives markets too. In recent years, the CFTC announced it would pursue corruption that affects the markets it regulates, such as bribes used to manipulate commodity prices or secure favorable trading conditions. That means a foreign bribery scheme touching oil, gas, agricultural, or other commodity markets may be reportable to the CFTC instead of, or in addition to, the SEC — under that program’s own 10–30% reward structure. An experienced attorney can help you determine which agency (or both) fits your information.
Real examples
Foreign bribery cases are among the largest enforcement actions in U.S. history, which is why the whistleblower awards tied to them can be so significant. In a landmark case, German engineering giant Siemens paid an $800 million penalty over a global bribery scheme. Sweden’s Ericsson paid over $1 billion to resolve bribery charges spanning multiple countries. France’s Alstom paid a $772 million penalty over a long-running scheme to bribe officials abroad. These cases show both the scale of the problem and the scale of the sanctions from which whistleblower awards are drawn.
The international reach is not theoretical. More than 2,000 non-U.S. citizens, from over 100 countries, have filed confidential whistleblower reports with the SEC — and insiders who witness bribery firsthand, in the country where it happens, often hold exactly the evidence the government needs.
A note on current enforcement
Like any law, FCPA enforcement priorities shift with each U.S. administration. In 2025, the FCPA went through a brief enforcement pause and a review of its guidelines, after which the U.S. Department of Justice issued updated enforcement guidelines and enforcement resumed, with foreign bribery remaining a stated priority. Throughout that period, the SEC and DOJ continued to accept whistleblower tips. The practical takeaway for a whistleblower is simple: the FCPA remains in force, the reward programs remain open, and credible information about foreign bribery is still valuable. Because priorities and timing can change, this is an area where speaking with an attorney about your specific situation is especially worthwhile.
Who can qualify
You do not need to be a U.S. citizen or live in the United States. Foreign nationals are explicitly eligible to be FCPA whistleblowers through the SEC program. Employees, former employees, agents, contractors, and others with original knowledge of a bribery scheme can all potentially qualify.
How to qualify
As with the SEC program generally, your information must be:
- Original — from your own knowledge or analysis, not already known to the government
- Voluntary — provided before any government request
- Specific and credible — strong enough to support an enforcement action
- Leading to sanctions over $1 million
Can you report anonymously, and do you need an attorney?
Yes — you can file anonymously through an attorney, just as with the broader SEC program. An attorney is required to file anonymously, and is strongly recommended in any case: foreign bribery investigations are complex and international, and skilled counsel helps you preserve evidence properly, navigate which agency to approach, protect you from retaliation, and maximize your potential award.
Beyond bribery: other fraud the SEC and CFTC reward
Foreign bribery is only one type of misconduct these two programs cover. If your information involves a company whose shares trade on a U.S. stock exchange, a wide range of securities fraud can be reported to the SEC for the same 10–30% reward — including accounting fraud and falsified financial statements, insider trading, market manipulation, misleading disclosures to investors, and fraud involving cryptocurrency and other securities. The SEC also pursues investment schemes that harm U.S. investors more broadly, such as Ponzi schemes and fraud by investment advisers, even where no U.S.-listed public company is involved.
The CFTC program rewards reporting of fraud and manipulation in the commodities and derivatives markets it regulates — for example, manipulating the price of a commodity, fraud in futures or swaps trading, or “spoofing” (placing fake orders to move a market). If you aren’t sure which agency fits your information, an experienced attorney can help you determine the right path — and in some cases, the same conduct can be reported to more than one program. For more detail, see our guides on reporting securities fraud under the SEC program and reporting commodities fraud under the CFTC program.
Where to report and learn more
For the full walkthrough, see our detailed guide, How to Report Bribery Under the Foreign Corrupt Practices Act, and our FCPA Complete FAQ. To discuss your situation privately, request a free and confidential consultation.
3. The IRS Whistleblower Program: Reporting Tax Fraud
A proven program built for large-scale tax fraud
If you have information about someone cheating on U.S. taxes on a large scale — especially through hidden offshore accounts or complex international schemes — this is your program. The IRS Whistleblower Office, created in 2007, is one of the most established and successful reward programs in the United States. It has helped the government collect more than $7.5 billion, and it has paid whistleblowers over $1.3 billion for their information.
Benefits and features
When your information leads the IRS to collect unpaid taxes, penalties, and interest, you may be eligible for an award of 15% to 30% of the amount the government collects. Because major tax-fraud cases can involve enormous sums, that share can be very large. The program also protects your identity to the fullest extent the law allows, and it provides anti-retaliation protections for employees who report.
What to report
The IRS is interested in significant tax violations — not small mistakes or minor underpayments. The kinds of cases it prioritizes include:
- Offshore tax evasion and hidden foreign bank accounts
- Large-scale corporate tax underpayment
- Transfer-pricing manipulation by multinational companies
- Abusive tax shelters and avoidance schemes
- Falsified deductions, unreported income, and employment-tax fraud
- Cryptocurrency and digital-asset tax noncompliance
This international dimension is why the program matters so much to whistleblowers abroad: foreign bankers, accountants, and advisers often have the clearest view of how U.S. taxpayers hide money overseas.
A real example
No case shows this better than our client Bradley Birkenfeld. As an American banker working at UBS in Switzerland, he exposed how the bank helped U.S. taxpayers conceal money in secret Swiss accounts. His disclosures forced UBS to reveal more than 4,450 account holders and pay a $780 million fine — and effectively ended the era of Swiss banking secrecy for American tax evaders. For his information, the IRS awarded him $104 million, among the largest individual whistleblower awards in history. It is the clearest possible proof that an insider, working outside the United States, can use this program to extraordinary effect.
Who can qualify
You do not need to be a U.S. citizen or live in the United States. Only individuals can file — companies and organizations cannot — and you cannot file based on information learned as a U.S. Treasury employee or certain other government roles. Bankers, accountants, advisers, employees, and others with firsthand knowledge of the fraud can all potentially qualify.
How to qualify
For the largest, mandatory award range, your case generally must meet specific dollar thresholds: the amount in dispute must exceed $2 million, and if the wrongdoer is an individual, that person must have annual gross income above $200,000. Your information must also be:
- Specific, timely, and credible — not a guess or a general suspicion
- Original — providing real value to the IRS, not merely repeating what is already public
- Submitted under penalty of perjury on the official form
One feature is especially important: the IRS generally pays the first person to come forward on a given fraud. If you wait, someone else may file first. This is a strong reason not to delay.
Two important differences from other programs
The IRS program has two features that set it apart, and you should understand them clearly:
- You cannot file anonymously. Unlike the SEC, CFTC, and FinCEN programs, the IRS does not allow anonymous award claims. You must identify yourself to the IRS. However, the IRS protects your identity from disclosure to the fullest extent the law allows, and keeps it confidential.
- It can take time. Tax cases move slowly. Because the IRS pays awards only after it has actually collected the money and all appeals are exhausted, it can take several years to receive an award. Patience is part of the process.
Do you need an attorney, and how do they help?
An attorney is not legally required to file, but it is strongly recommended — and because the IRS doesn’t offer anonymous filing, skilled counsel is especially valuable here. A whistleblower attorney helps you build a submission that meets the IRS’s standards, present your evidence persuasively, protect your confidentiality and your job, and argue for the highest award percentage. Filing is done using IRS Form 211, “Application for Award for Original Information.”
Where to report and learn more
For the full step-by-step process, see our International Whistleblower’s Guide to Reporting Tax Evasion to the IRS and our IRS Whistleblower Program FAQ for international whistleblowers. To discuss your situation confidentially, request a free and confidential consultation.
4. The False Claims Act (Qui Tam): Reporting Fraud Against the U.S. Government
The oldest and most different of the programs
The False Claims Act is the United States’ oldest whistleblower law, dating back to 1863, and it works differently from every other program in this guide. The others involve submitting a tip to a government agency. The False Claims Act instead lets you file an actual lawsuit — on behalf of the U.S. government — against whoever defrauded it. This is called a qui tam action, and the whistleblower who brings it is called a “relator.”
That difference shapes everything about how this program works, so we’ll explain it plainly.
What to report
The False Claims Act covers fraud against the U.S. government itself — situations where someone lies to the government to get paid, or to avoid paying what they owe. Common examples include:
- Healthcare fraud, such as billing Medicare or Medicaid for services never provided
- Defense and government contract fraud — overcharging, billing for defective products, or failing to deliver what was promised
- Grant fraud and misuse of federal funds
- Customs fraud, such as evading import duties owed to the United States
- Falsely certifying compliance with federal requirements to win or keep a contract
Benefits and features
This is one of the most financially powerful whistleblower laws in the world. Wrongdoers found liable face triple the government’s losses plus per-claim penalties — and the relator who brought the case receives a share of whatever the government recovers. That share is 15% to 30% of the total recovery, and it comes directly out of the recovery itself, not from taxpayers. The law also strongly protects employees from retaliation: a worker fired or punished for blowing the whistle may be entitled to reinstatement, double back pay, and attorneys’ fees.
The numbers show the scale. In a single recent year, the government recovered a record $6.8 billion under the False Claims Act, the vast majority of it driven by whistleblower lawsuits. Since the law was strengthened in 1986, qui tam relators have helped recover tens of billions of dollars.
Real examples
Our firm has used this law to hold powerful institutions accountable. We represented whistleblower James Connolly, who used the California False Claims Act to expose how the multinational bank HSBC defrauded CalPERS — a public pension fund — out of $7 million. In another case, our client Dr. Aaron Westrick, a body-armor company research director, filed a False Claims Act lawsuit after his employer continued selling bulletproof vests made with a fiber that degraded over time — vests sold to police and the U.S. government. His case shows that qui tam isn’t only about money: sometimes it’s about lives.
How it works: the unique process
A qui tam case follows a path you won’t find in the other programs:
- Your attorney files a complaint under seal in federal court. “Under seal” means the case is secret — the public, and even the company you’re reporting, are not told. This protects your identity during the early stages.
- The complaint is shared confidentially with the U.S. Department of Justice, along with a statement of your evidence.
- The government investigates and decides whether to “intervene” (join and take the lead on your case) or to let you proceed on your own.
- If the case succeeds, you receive your share of the recovery as the relator.
Two rules matter enormously here. First, you generally must be the first to file on a particular fraud — if someone else has already brought the same case, you are barred. Second, your case generally cannot be based on fraud that has already been publicly disclosed; it needs to rest on what you know that the public does not. Both rules reward acting promptly and confidentially.
Who can qualify
International whistleblowers can bring qui tam cases — you do not need to be a U.S. citizen or live in the United States. Relators are often insiders: employees, former employees, contractors, or competitors with direct evidence of the fraud.
Do you need an attorney?
Yes — always, without exception. This is the single most important thing to understand about the False Claims Act. Because a qui tam case is a lawsuit filed in federal court, the law requires you to be represented by a U.S.-based attorney. This is true whether or not your filing is under seal, and it is true for every relator. You cannot file a qui tam case on your own.
That requirement is also a strength. An experienced qui tam attorney drafts the complaint, assembles your evidence, navigates the sealed-court process, manages the relationship with the Department of Justice, and fights for the highest possible relator’s share. The complexity of these cases is exactly why skilled counsel is indispensable.
Where to report and learn more
For more, see our False Claims Act FAQ for international whistleblowers and our qui tam practice area. Because every qui tam case requires an attorney from the very start, the best first step is a free and confidential consultation.
Recommended Steps: Where to Go From Here
You’ve now learned the basics of how U.S. whistleblower laws work and which programs may fit your situation. That is a real accomplishment — most people never get this far. If you believe you have information worth reporting, here is how to move forward safely and wisely.
1. Talk to a whistleblower attorney first
Before you do anything else — before you file anything, gather more evidence, or tell anyone — speak with an experienced whistleblower attorney. This is the most important step, and there are good reasons it comes first.
A skilled attorney helps you understand whether you actually have a case, which program fits best, and how to proceed without making a costly mistake. For some programs, an attorney is required: you cannot file anonymously with the SEC, CFTC, or FinCEN without one, and you cannot file a False Claims Act case at all without one. Even where an attorney isn’t strictly required, having one dramatically strengthens your position and protects you. Most reputable whistleblower firms, including ours, offer a free and fully confidential consultation, so this first step costs you nothing.
2. If your situation allows it, follow the right reporting process
Each program has its own path — a tip submitted through an attorney, an official form, or a lawsuit filed under seal. Once you’ve spoken with counsel and understand your options, you can follow the correct process for your program. The detailed, step-by-step guides linked throughout this page walk through exactly how each one works. Don’t try to navigate the filing process alone or in a hurry; the order in which you do things can affect both your protection and your potential award.
3. Protect yourself: stay secure, stay quiet, and never use company devices
This may be the most important practical advice in this entire guide. How you handle yourself before you report can make or break your case — and your safety.
- Keep it to yourself. Do not discuss what you know with coworkers, friends, or on social media. The fewer people who know, the safer you are, and the stronger your case remains. In several programs, information that has already become public can disqualify you.
- Never use company devices or accounts. Do not research whistleblowing, contact an attorney, or store evidence on a work computer, work phone, or company email. Employers can monitor these. Use a personal device on a private connection.
- Gather evidence lawfully. Preserve documents and records you already have legitimate access to — but do not hack, steal, or take materials you aren’t authorized to access. Improperly obtained evidence can harm your case and expose you to legal risk. When in doubt, ask your attorney before collecting anything.
- Be especially careful where speaking up carries risk. In many countries, reporting corruption can bring real danger — professional, legal, or personal. If you live somewhere that whistleblowing is dangerous or taboo, confidentiality is not just strategy, it’s protection. The U.S. programs’ confidentiality and anonymous-filing options exist in part for exactly this reason, and a good attorney will help you use them.
4. Understand what comes next: rewarding, but life-changing
We want to be honest with you. Blowing the whistle can be one of the most meaningful things a person ever does — and it can change your life in ways both good and hard. The financial rewards can be substantial, and the satisfaction of stopping serious wrongdoing is real. But these cases can also take years to resolve, demand patience, and carry personal and professional weight along the way.
You do not have to carry that alone. The right legal team handles the process for you, protects your identity, shields you from retaliation, and stands between you and the people you’re reporting. Going in with clear expectations — and good support — is what turns a frightening decision into a manageable one.
Take the next step
If you think you may have information about fraud, corruption, money laundering, sanctions evasion, tax fraud, or bribery, you don’t have to figure it out by yourself. International Whistleblower Advocates offers a free and fully confidential consultation. We will listen to your situation, help you understand your options, and tell you honestly whether you may have a case — with no obligation and complete discretion.
