Whistleblower protections under pressure: Addressing barriers to effectiveness
Co-organised with the UNGC PRME Working Group on Anti-Corruption and the OECD Whistleblowers are crucial in the fight against bribery and corruption, but ensuring their protection and support remains a global challenge. Despite the establishment of legal frameworks and protection mechanisms in numerous countries, significant gaps persist in making these systems both effective and accessible. Whistleblowers often face fears of retaliation, fragmented reporting channels, and uncertainty about whether their reports will reach the right authorities or lead to meaningful action. This session will explore how the multiplicity of reporting mechanismsâacross public and private sectorsâcan create confusion for whistleblowers and complicate the processing and response to reports.
Participants will examine how enforcement authorities and organizations can effectively manage increasing volumes of whistleblower reports, ensuring they are directed to the appropriate bodies and acted upon in a timely manner. Discussions will also address gaps in legal frameworks, the enforcement of protections, and strategies to build trust in reporting mechanisms. Additionally, the session will address the issue of incentivizing whistleblowersâensuring they are not only protected but also motivated to come forward through recognition, support, and fair treatment. By fostering a culture of trust and accountability, whistleblower mechanisms can be strengthened to play a pivotal role in combating corruption worldwide.
Special Discussion: Effective Responses to the Current Crisis in the United States
Panelists will focus on anti-corruption strategies and how to execute them effectively, in light of the crises in the United States.
Speakers include:
Stephen M. Kohn
is a partner in the law firm of Kohn, Kohn and Colapinto and the Chairman for the Board of the National Whistleblower Center. As a leading whistleblower attorney with 40 years of experience Forbes Magazine honored Kohn, selecting him as one of âAmericaâs top 200 lawyersâ  explaining that Kohn âchange[ed]â the âlegal landscapeâ for whistleblowers as he  âHe won $104 million for UBS whistleblower Bradley Birkenfeld, among the largest-ever individual tax whistleblower reward payments, and currently represents Danske Bank whistleblower Howard Wilkinson in its massive money-laundering scandal. Kohn has helped draft key whistleblower legislation and regulation, including those incorporated into the Sarbanes-Oxley and Dodd-Frank acts.â Kohn is the most published author on whistleblower law, and his latest book is Rules for Whistleblowers: A Handbook for Doing Whatâs Right (Lyons Press).
Christopher Wylie
a British-Canadian whistleblower, is best known for exposing massive privacy violations by Facebook and Cambridge Analytica, and the misuse of millions of Facebook profiles in the groundbreaking Guardian exposĂ©: âRevealed: 50 million Facebook profiles harvested for Cambridge Analytica in major data breach; Whistleblower describes how firm linked to former Trump adviser Steve Bannon compiled user data to target American voters.â He was the first successful Big Tech/social media whistleblower whose disclosures resulted in billions of dollars in fines and significant corporate reforms. Wylie was recognized in Time magazine’s list of the 100 Most Influential People and is also the author of *Mindf*ck: Cambridge Analytica and the Plot to Break America.*
Eliza Lockhart
is an attorney and Research Fellow at the Centre for Finance and Security at the Royal United Services Institute (RUSI), the oldest and most prestigious think tank in the UK. She is the author of the groundbreaking RUSI study titled âThe Role of Financial Rewards for Whistleblowers in the Fight Against Economic Crime.â Eliza has provided counsel on anti-bribery and corruption matters, including issues related to election fraud, risk, and compliance. She holds a Master of Law and an MPhil in Public Policy, both with Distinction from the University of Cambridge.
MarĂa de los Ăngeles Estrada
is a Mexican lawyer specializing in transparency and anti-corruption. She previously served as the Executive Director of the Transparency and Anti-corruption Initiative of the School of Government and Public Transformation of the Tec de Monterrey, one of the most important and renowned universities in Latin America. Â She has a law degree from ITAM and a Masterâs in International Law from The Fletcher School at Tufts University. Â She currently leads the Transparency, Anti-Corruption, and Digitalization Initiative in Mexico and teaches courses on transparency and anti-corruption at TecnolĂłgico de Monterrey, El Colegio de MĂ©xico, and the Anticorruption Institute of Colombia.
Emin Huseynov
is a prominent Azerbaijani human rights defender, journalist, and whistleblower-advocate. He was the chairman of the Institute for Reporters’ Freedom and Safety in Azerbaijan before being forced into hiding to avoid arrest due to his human rights advocacy and reporting. He spent 10 months in refuge at the Swiss Embassy in Baku, Azerbaijanâs capital, after being placed on a wanted list in connection with criminal proceedings against his media freedom group amid a widespread crackdown on independent media and non-government organizations and is currently living in exile in Switzerland. In 2023, the European Court of Human Rights awarded Emin compensation, finding that the Azerbaijani authorities violated his human rights when they stripped him of his Azerbaijani citizenship. Today, Emin serves as the Chief Executive Officer of the Institute for Human Rights.
Eric Hylton
is the former Deputy of the IRSâs Criminal Investigation Division and head of International Operations. He oversaw the sixth-largest US Federal law enforcement agency, with a worldwide staff of approximately 3,000 employees that resulted in over 6,000 investigations recommended for prosecution, leading to thousands of individuals convicted and sentenced. Eric also served as the chair for the OECDâs Task Force for Tax Crimes and Other Financial Crimes. As Chair, Eric led a multilateral commission of 40 international criminal tax organizations to develop methodologies and typologies on emerging global criminal tax and financial crime threats.  Eric is currently an attorney for the Alliant Group and a member of the Tax  Whistleblower Attorney Group.
Background Information and Key Reports:
Stephen Kohnâs recent article in the NYU Compliance and Enforcement Blog, âCrippling the FCPA is Bad Business for the U.Sâ discusses how the FCPA protects American competitiveness. He produces research which shows how FCPA enforcements primarily target foreign companies.
Two-time FBI whistleblower Jane Turner interviewed Stephen Kohn on a recent episode of the Whistleblower Network News podcast Whistleblower of the Week to discuss developments in U.S enforcement of the FCPA. Listen to Kohn and Turner discuss Kohnâs recent research and outline strategies to move forward.
In December 2024, the Royal United Services Institute (âRUSIâ) released the groundbreaking report âThe Inside Track: The Role of Financial Rewards for Whistleblowers in the Fight Against Economic Crimeâ by Eliza Lockhart. The report concludes that the UK should institute a whistleblower reward scheme similar to the United States, signaling a massive shift in UK whistleblower policy.
- âThe Role of Financial Rewards for Whistleblowers in the Fight Against Economic Crime,â Eliza Lockhart, Research Fellow (December 2024)
- Financial Rewards for Whistleblowers in the Fight Against Economic Crime, Briefing Note by Eliza Lockhart, Research Fellow (December 2024)
- Recording: Whistleblowersâ Rewards in the Fight Against Economic Crime, panel discussion with SFO Director Nick Ephgrave, Ashurst partner Judith Seddon, and Spotlight on Corruption Director Sue Hawley.
- âMoney Talks: Financially Rewarding Economic Crime Whistleblowers,â by Eliza Lockhart, Research Fellow (December 2024)
- âEpisode 11: Incentivizing Whistleblowers to Expose Economic Crime,â podcast with CFS Director Tom Keatinge, Nick Ephgrave and Eliza Lockhart (January 2025).
The OECD Anti-Corruption Convention on Combatting Bribery of Foreign Public Officials in International Business Transactions is an international agreement for OECD countries to combat corruption.
- OECD Recommendation of the Council for Further Combating Bribery of Foreign Public Officials
- Implementing the OECD Anti-Bribery Convention Phase IV Report to the United States (HYPERLINK ATTACHED DOC HERE)
- Implementing the OECD Anti-Bribery Convention Phase IV 2-Year Follow Up Report to the United States