Corruption is the misuse of a position of trust \u2014 public or private \u2014 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.<\/p>\n\n\n\n
There is no single, official United Nations definition of corruption \u2014 and the UN says so itself. The UN Office on Drugs and Crime’s own Anti-Corruption Toolkit<\/a> states plainly that “there is no single, comprehensive, universally accepted definition of corruption.”<\/p>\n\n\n\n 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.<\/p>\n\n\n\n It also reaches across nearly every sector \u2014 government, business, the courts, media, and civil society \u2014 with particularly well-documented impacts in healthcare, education, infrastructure, and sports.<\/p>\n\n\n\n International law looks at the UN’s own list-based approach for addressing such corrupt activities.<\/p>\n\n\n\n The United Nations Convention against Corruption<\/a> (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.<\/p>\n\n\n\n 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 \u2014 and the second one is what determines whether a whistleblower has a case.<\/p>\n\n\n\n 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:<\/p>\n\n\n\n U.S.-based international whistleblower reward programs are built almost entirely around grand corruption \u2014 bribery of foreign officials, large-scale money laundering, and major tax fraud \u2014 because that is where the financial sanctions large enough to fund an award tend to arise.<\/p>\n\n\n\n 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:<\/p>\n\n\n\n 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.<\/p>\n\n\n\n Corruption rarely moves through the financial system on its own \u2014 it typically needs help.<\/p>\n\n\n\n The U.S. Department of the Treasury has pointed to the role that “key gatekeepers to the financial system<\/a> \u2014 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.<\/p>\n\n\n\n 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.<\/p>\n\n\n\n Corruption is difficult to quantify because, in the World Bank’s own words, it is “by its very nature, difficult to detect<\/a>” \u2014 most of it goes unreported and unrecorded, which makes the true scale of the problem nearly impossible to calculate.<\/p>\n\n\n\n In a 2018 statement to the UN Security Council<\/a>, then\u2013UN Secretary-General Ant\u00f3nio 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.<\/p>\n\n\n\n Think about it this way, in 2025, all OECD donor countries combined gave $174.3 billion in official development assistance<\/a> \u2014 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.<\/p>\n\n\n\n The World Bank’s own more recent research, however, is notably cautious about figures like these.<\/p>\n\n\n\n Its current published assessment<\/a> 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.<\/p>\n\n\n\n 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.<\/p>\n\n\n\n On enforcement, FCPA cases show the same pattern at scale.<\/p>\n\n\n\n In October 2020, Goldman Sachs agreed to pay more than $2.9 billion<\/a> to the DOJ and SEC to resolve FCPA charges tied to the 1MDB scandal \u2014 bribes paid to officials in Malaysia and Abu Dhabi to win $6.5 billion in bond underwriting business \u2014 making it, at the time, the largest FCPA resolution in history.<\/p>\n\n\n\n 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<\/a> that keep the statute active but more narrowly targeted.<\/p>\n\n\n\n Across enforcement cycles, the underlying pattern persists: it is almost always an insider \u2014 a compliance officer, a local finance employee, a subsidiary manager \u2014 who first surfaces a bribery scheme, not an outside investigator.<\/p>\n\n\n\n The financial toll is only part of the picture.<\/p>\n\n\n\n The preamble to the UNCAC<\/a> 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.<\/p>\n\n\n\n The scale remains substantial: as of December 2025, UNDP estimates that $2 trillion<\/a> is stolen, laundered, and hidden from governments and communities worldwide every year, and that, according to UNODC, between 10 and 25%<\/a> of the value of any given government contract may be lost to corruption.<\/p>\n\n\n\n The UNCAC treaty mandates its states parties \u2014 which includes nearly every country in the world \u2014 to criminalize bribery of national public officials, embezzlement, trading in influence, and money laundering, and to establish methods for international cooperation and asset recovery.<\/p>\n\n\n\n The treaty also requires states parties to criminalize the solicitation side of bribery \u2014 a public official demanding or accepting an undue advantage \u2014 not only the offering side, which is why extortion by officials falls within the same legal framework as bribery.<\/p>\n\n\n\n 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:<\/p>\n\n\n\n Odebrecht and Braskem \u2014 the largest foreign bribery case in history.<\/strong> In December 2016, the Brazilian construction conglomerate Odebrecht and its petrochemical affiliate Braskem pleaded guilty to paying approximately $788 million in bribes<\/a> 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 \u2014 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.<\/p>\n\n\n\n Howard Wilkinson and Danske Bank \u2014 money laundering at scale.<\/strong> Our client Howard Wilkinson, a British manager at Danske Bank’s Estonian branch, uncovered roughly $230 billion in suspicious payments \u2014 much of it Russian money \u2014 flowing through the bank and into the U.S. financial system, in what is widely described as the largest money laundering scandal in history<\/a>. His disclosures reshaped how regulators think about cross-border money laundering risk.<\/p>\n\n\n\n Bradley Birkenfeld and UBS \u2014 corruption through hidden wealth.<\/strong> 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<\/a> from the IRS \u2014 among the largest individual whistleblower awards in history.<\/p>\n\n\n\n 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.<\/p>\n\n\n\n Four programs cover the large majority of international corruption cases:<\/p>\n\n\n\n Awards under every one of these programs are conditional \u2014 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.<\/p>\n\n\n\n Which program fits depends on what kind of corruption you witnessed, who was involved, and whether U.S. jurisdiction is likely to reach it.<\/p>\n\n\n\n Our full walkthrough \u2014 International Whistleblowing 101: A Guide for Global Whistleblowers<\/a> \u2014 covers each program in detail, including how to qualify, whether you can file anonymously, and what protections apply.<\/p>\n\n\n\n As a starting point:<\/p>\n\n\n\n Document what you observed, preserve evidence lawfully, and speak with an experienced whistleblower attorney before you report anything \u2013 especially if you live in a country where safety is a concern.<\/p>\n\n\n\nKey Takeaways<\/h2>\n\n\n\n
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Comparing Levels of Corruption<\/h2>\n\n\n\n
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Forms of Corruption<\/h2>\n\n\n\n
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Corruption’s Professional Enablers<\/h2>\n\n\n\n
The Scale of the Problem<\/h2>\n\n\n\n
How Big Is the Problem?<\/h3>\n\n\n\n
Why the Numbers Are Unreliable<\/h3>\n\n\n\n
Enforcement Shows the Same Pattern<\/h3>\n\n\n\n
Beyond the Financial Toll<\/h3>\n\n\n\n
Is Corruption Illegal?<\/h2>\n\n\n\n
Under International Law<\/h3>\n\n\n\n
In the United States<\/h3>\n\n\n\n
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Real-World Examples<\/h2>\n\n\n\n
Corruption and Whistleblowing<\/h2>\n\n\n\n
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How to Report Corruption<\/h2>\n\n\n\n
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Get Legal Assistance<\/h2>\n\n\n\n