Corruption

What Is Corruption?

Corruption is the misuse of a position of trust — public or private — for personal or organizational benefit, and internationally it covers a defined set of offenses: bribery, embezzlement, trading in influence, abuse of functions, money laundering, and related conduct.

There is no single, official United Nations definition of corruption — and the UN says so itself. The UN Office on Drugs and Crime’s own Anti-Corruption Toolkit states plainly that “there is no single, comprehensive, universally accepted definition of corruption.”

Corruption is a parent term that encompasses many different illegal activities. Corruption can involve a customs official, a company executive, a procurement officer, or a head of state, and it can take the form of a bribe, a stolen contract, a falsified account, or a demand backed by a threat.

It also reaches across nearly every sector — government, business, the courts, media, and civil society — with particularly well-documented impacts in healthcare, education, infrastructure, and sports.

International law looks at the UN’s own list-based approach for addressing such corrupt activities.

The United Nations Convention against Corruption (UNCAC), the only legally binding global anti-corruption treaty, requires states to criminalize a defined set of acts, which include bribery of public officials, embezzlement, trading in influence, abuse of functions, illicit enrichment, and money laundering, among others.

This matters for individuals trying to understand their own situation, because whether something is considered “corruption” in the everyday sense and whether it is a specific prosecutable offense are two different questions — and the second one is what determines whether a whistleblower has a case.

Key Takeaways

• There is no single definition of corruption — the UN’s own Anti-Corruption Toolkit says so directly — and international law instead criminalizes it through a specific list of offenses rather than one catch-all crime.
• The UNCAC has been ratified by nearly every UN member state and is the primary international legal framework governing anti-corruption enforcement and cooperation.
• World leaders frequently cite figures for the global cost of corruption. A popular estimate is that more than $2.6 trillion, or 5% of global GDP, is lost to corruption annually around the world.
• Many U.S. whistleblower laws have transnational reach and tackle corruption happening anywhere in the world, as long as it touches the U.S. financial system, U.S. markets, or a company connected to the United States.
• Whistleblowers who report qualifying corruption can be eligible for financial awards, typically 10–30% of sanctions collected, though eligibility always depends on the specific program and facts.

Comparing Levels of Corruption

Not all corruption is the same, and this is important when talking about enforcement and international transparency. Below are the broad categories and their definitions:

• Grand corruption: this often involves officials or executives in positions of power engaging in corrupt activities such as bribery, embezzlement, or money laundering, among others. It damages national policy or disrupts the functioning of entire institutions. This is the category international whistleblower reward laws are generally built to address – generally involving issues in the millions, if not billions, of dollars.
• Petty corruption: involves everyday abuse low-level officials commit in their dealings with ordinary people — a clerk demanding a small payment to process a permit that should be free. It is common, but rarely the subject of major transnational enforcement given the low insubstantial amounts involved.
• Political corruption involves the manipulation of laws, institutions, and rules of procedure by those who hold political power, often to keep or extend that power — including vote-buying, illicit campaign financing, and state capture. This type of corruption is harder to enforce using transnational U.S. laws as it does not generally affect the U.S. or its citizens directly.

U.S.-based international whistleblower reward programs are built almost entirely around grand corruption — bribery of foreign officials, large-scale money laundering, and major tax fraud — because that is where the financial sanctions large enough to fund an award tend to arise.

Forms of Corruption

Corruption can take on many specific forms. Some of the most significant, particularly for international whistleblowers and what current FCPA enforcement statistics tell us, include:

• Bribery — offering, giving, receiving, or soliciting something of value to influence an official act or business decision.
• Extortion — obtaining money or an advantage through threat, intimidation, or the misuse of official power; the demand-side mirror of bribery.
• Money laundering — disguising the origin of illegally obtained money to make it appear legitimate, often the mechanism that moves the proceeds of other corrupt acts through the financial system.
• Embezzlement — a person entrusted with property or funds, typically a public official or employee, misappropriating them for personal use.
• Nepotism and cronyism — using power to benefit relatives or associates, regardless of merit, in hiring, contracts, or promotions.
• Trading in influence — offering or accepting an undue advantage in exchange for someone abusing their real or supposed influence over a decision.
• Abuse of functions — a public official performing, or failing to perform, an official act, in violation of law, for personal benefit or gain.
• Illicit enrichment — a significant, unexplained increase in a public official’s assets or the value of those assets relative to their lawful income.
• Procurement and contract fraud — rigging bids, inflating costs, or falsifying compliance to win or keep government or corporate contracts.
• Tax fraud and evasion — illegally avoiding tax obligations through hidden accounts, shell companies, or falsified records; seen as a corruption-adjacent offense when it involves public officials or organized schemes.
• Market manipulation — corrupt payments or conduct used to distort commodities, securities, or derivatives markets.

This list is not exhaustive. Patronage, conflict of interest, and solicitation are other related forms of corruption that will be covered in their own entries in this entry.

Corruption’s Professional Enablers

Corruption rarely moves through the financial system on its own — it typically needs help.

The U.S. Department of the Treasury has pointed to the role that “key gatekeepers to the financial system — like accountants, investment advisers, lawyers, and others” play in corruption and other financial crime, noting that corrupt actors depend on these professionals and “financial enablers” to launder stolen funds through the U.S. and international financial systems.

This is also why these same professionals are so often the ones positioned to notice something is wrong. A lawyer asked to set up an opaque offshore structure, an accountant reviewing books that don’t add up, or a bank employee processing transactions that don’t match a client’s stated business are frequently the first people to see a corruption scheme for what it is.

The Scale of the Problem

How Big Is the Problem?

Corruption is difficult to quantify because, in the World Bank’s own words, it is “by its very nature, difficult to detect” — most of it goes unreported and unrecorded, which makes the true scale of the problem nearly impossible to calculate.

In a 2018 statement to the UN Security Council, then–UN Secretary-General António Guterres cited two figures: the World Economic Forum’s estimate that the global cost of corruption is at least $2.6 trillion, or 5% of global GDP, and the World Bank’s estimate that businesses and individuals pay more than $1 trillion in bribes every year.

Think about it this way, in 2025, all OECD donor countries combined gave $174.3 billion in official development assistance — the total global aid budget, worldwide, for the year. The $1 trillion paid in bribes is more than 5.5 years’ worth of all the world’s combined foreign aid, paid out in bribes every single year.

Why the Numbers Are Unreliable

The World Bank’s own more recent research, however, is notably cautious about figures like these.

Its current published assessment states that a review of the most-cited global corruption statistics found that all of them rest on fragile foundations, and concludes that there are, at present, no credible estimates of the global cost of corruption at all. Again, given its nature to obfuscate.

What is not in dispute is the direction of the harm: corruption research consistently shows that it diverts money from schools, hospitals, and infrastructure, and discourages investment.

Enforcement Shows the Same Pattern

On enforcement, FCPA cases show the same pattern at scale.

In October 2020, Goldman Sachs agreed to pay more than $2.9 billion to the DOJ and SEC to resolve FCPA charges tied to the 1MDB scandal — bribes paid to officials in Malaysia and Abu Dhabi to win $6.5 billion in bond underwriting business — making it, at the time, the largest FCPA resolution in history.

Enforcement isn’t static: in February 2025, a presidential executive order paused new FCPA investigations for several months, before the DOJ resumed enforcement that June under revised guidelines that keep the statute active but more narrowly targeted.

Across enforcement cycles, the underlying pattern persists: it is almost always an insider — a compliance officer, a local finance employee, a subsidiary manager — who first surfaces a bribery scheme, not an outside investigator.

Beyond the Financial Toll

The financial toll is only part of the picture.

The preamble to the UNCAC states that corruption threatens the stability and security of societies, undermines the institutions and values of democracy and justice, and jeopardizes both the rule of law and sustainable development.

The scale remains substantial: as of December 2025, UNDP estimates that $2 trillion is stolen, laundered, and hidden from governments and communities worldwide every year, and that, according to UNODC, between 10 and 25% of the value of any given government contract may be lost to corruption.

Is Corruption Illegal?

Under International Law

The UNCAC treaty mandates its states parties — which includes nearly every country in the world — to criminalize bribery of national public officials, embezzlement, trading in influence, and money laundering, and to establish methods for international cooperation and asset recovery.

The treaty also requires states parties to criminalize the solicitation side of bribery — a public official demanding or accepting an undue advantage — not only the offering side, which is why extortion by officials falls within the same legal framework as bribery.

In the United States

U.S. law tackles corruption through various statutes rather than one “corruption law,” and several of them apply even when the underlying conduct happens outside the United States. Below are some of those laws:

• The Foreign Corrupt Practices Act (FCPA) makes it illegal for companies connected to the U.S. to bribe foreign officials to win or keep business, and requires accurate books and records.
• The Bank Secrecy Act, as expanded by the Anti-Money Laundering Act of 2020 (AMLA), criminalizes money laundering and sanctions evasion and — through its whistleblower program — rewards individuals who report violations to FinCEN.
• The IRS Whistleblower Program rewards individuals who report tax fraud or underpayment to the IRS, offering awards of 15–30% of the proceeds collected in qualifying cases.
• The Foreign Extortion Prevention Act (FEPA), now at 18 U.S.C. § 1352, closed a long-standing gap by making it a crime for a foreign official to demand a bribe from a U.S. person, company, or issuer.
• The False Claims Act (FCA) addresses fraud against the federal government, most commonly in government contracting, and allows whistleblowers to file qui tam suits on the government’s behalf.

Real-World Examples

Odebrecht and Braskem — the largest foreign bribery case in history. In December 2016, the Brazilian construction conglomerate Odebrecht and its petrochemical affiliate Braskem pleaded guilty to paying approximately $788 million in bribes to government officials in twelve countries across Latin America and Africa to secure more than 100 infrastructure and public works projects. The companies agreed to pay a combined $3.5 billion in penalties to authorities in the U.S., Brazil, and Switzerland — the largest global foreign bribery resolution ever reached. The scheme reached the highest levels of Brazil’s state-controlled oil company, Petrobras, and helped trigger the “Lava Jato” (Car Wash) investigation that reshaped Latin American politics.

Howard Wilkinson and Danske Bank — money laundering at scale. Our client Howard Wilkinson, a British manager at Danske Bank’s Estonian branch, uncovered roughly $230 billion in suspicious payments — much of it Russian money — flowing through the bank and into the U.S. financial system, in what is widely described as the largest money laundering scandal in history. His disclosures reshaped how regulators think about cross-border money laundering risk.

Bradley Birkenfeld and UBS — corruption through hidden wealth. As an American banker at UBS in Switzerland, our client Bradley Birkenfeld exposed how the bank helped thousands of U.S. taxpayers conceal money in secret offshore 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 — among the largest individual whistleblower awards in history.

Corruption and Whistleblowing

Corruption is rarely uncovered from the outside due to how tightly sealed corporations operate. It is uncovered by the people closest to it: the insiders. The compliance officer who sees the falsified records, the bank employee who notices the suspicious wire transfers, the contractor who is asked to pad an invoice. U.S. law gives those insiders a channel to report it, wherever in the world they are located. And in many cases a financial stake in the outcome.

Four programs cover the large majority of international corruption cases:

• The FinCEN Anti-Money Laundering & Sanctions Program — for money laundering, sanctions evasion, and Bank Secrecy Act violations. Awards, when the program’s rules are finalized, are expected to run 10–30% of sanctions collected over $1 million.
• The FCPA, reported through the SEC or CFTC Whistleblower Programs — for foreign bribery, with awards of 10–30% of sanctions collected over $1 million.
• IRS Whistleblower Program — for large-scale tax fraud and offshore evasion, with awards of 15–30% of amounts collected.
• False Claims Act (qui tam) — for corruption involving fraud against the U.S. government, with a relator’s share of 15–30% of the recovery.

Awards under every one of these programs are conditional — they depend on the information being original, the case meeting statutory thresholds, and an enforcement action actually succeeding. But for a whistleblower with strong, firsthand information about grand corruption, these are the most established reward laws in the world, and they are open to non-U.S. citizens who have never set foot in the United States.

How to Report Corruption

Which program fits depends on what kind of corruption you witnessed, who was involved, and whether U.S. jurisdiction is likely to reach it.

Our full walkthrough — International Whistleblowing 101: A Guide for Global Whistleblowers — covers each program in detail, including how to qualify, whether you can file anonymously, and what protections apply.

As a starting point:

• Money laundering, sanctions evasion, or bank compliance failures → FinCEN
• Bribery of a foreign official by a company connected to the U.S. → SEC or CFTC, under the FCPA
• Large-scale tax evasion involving U.S. taxpayers → IRS
• Fraud against the U.S. government — contracts, grants, healthcare → False Claims Act (qui tam)

Get Legal Assistance

Document what you observed, preserve evidence lawfully, and speak with an experienced whistleblower attorney before you report anything – especially if you live in a country where safety is a concern.

Most of these programs require an attorney to file anonymously, and the False Claims Act requires one regardless whether you file anonymously or not. International Whistleblower Advocates offers a free, confidential consultation to help you understand your options.

Frequently Asked Questions

Is corruption illegal everywhere?

Just about every country has ratified the UNCAC and committed to criminalizing bribery, embezzlement, and related conduct — but enforcement varies enormously by country. That gap is one of the main reasons U.S. whistleblower laws matter so much to people reporting corruption abroad: they can apply even where local enforcement is weak or nonexistent.

What’s the difference between corruption and fraud?

Corruption specifically involves the abuse of entrusted power — a position of trust, public or private. Fraud is a broader category of intentional deception for financial gain that does not necessarily involve a position of trust at all.

Many corruption schemes also involve fraud, such as falsifying records to hide a bribe. In the U.S., Ponzi schemes are a prevalent type of fraud. They are designed to pay older investors using money collected from newer investors instead of actual profits.

How much does corruption cost the global economy?

Tracking corruption is difficult because it’s hard to detect and quantify. However, citing the World Bank and World Economic Forum, the UN Secretary-General has stated that businesses and individuals pay over $1 trillion in bribes annually, with the broader global cost of corruption estimated at $2.6 trillion, or about 5% of global GDP.

Can I get a financial reward for reporting corruption?

In many cases, yes. Programs run by the SEC, CFTC, IRS, and FinCEN, along with the False Claims Act, offer awards — typically 10–30% of the amount collected — to whistleblowers whose original information leads to a successful enforcement action meeting the program’s thresholds. Eligibility always depends on the specific facts, which is why speaking with an attorney early matters.

Do I need to be a U.S. citizen to report corruption to a U.S. agency?

No. All of the major U.S. whistleblower programs — FinCEN, the SEC and CFTC (including FCPA cases), the IRS, and the False Claims Act — are open to whistleblowers regardless of nationality or where they live, as long as the underlying conduct touches U.S. markets, the U.S. financial system, or a company connected to the United States.

Get Legal Help Today

Corruption thrives on silence — the assumption that nothing will change, or that the person who speaks up will be the one who pays the price. The whistleblowers behind some of the largest corruption cases in history were ordinary employees who happened to be in the right place to see what was happening, and who decided to say something.

If you’ve witnessed bribery, money laundering, embezzlement, or another form of corruption, the first step is a confidential conversation about your options. Our team offers confidential consultations for whistleblowers worldwide.