The landscape of international anti-corruption has become both more perilous urgent in 2025. As recently discussed, the National Whistleblower Center (NWC) underscored how, in the face of funding crises and shrinking civic space at the United Nations Convention against Corruption (UNCAC), global civil society faces exclusion and unprecedented headwinds.
The question for the coming years is not just whether governments will allow civic voices at the table—but who, exactly, will step up and lead global anti-corruption efforts now that the United States has signaled retreat?
In this Sunday Read, we’ll explore this conundrum and how the “Reverse Marshall Plan” provides guidance for international leaders of liberal democracies, particularly those who will be attending the 11th Session of the Conference of the State Parties (CoSP11) (or CoSP to the UNCAC) in Doha, Qatar from December 14–19.
The New Void: U.S. Policy Shift and Its Aftermath
Historically, American leadership provided critical funding and set the standard for robust enforcement—chiefly through the Foreign Corrupt Practices Act (FCPA). This position demonstrated to the world that successful programs were supported through a combination of adequate funding and multi-agency transparency following resolutions. This cycle encourages other whistleblowers to step forward.
Yet, with the Trump Administration’s freeze on U.S. FCPA enforcement and deep cuts to USAID and anti-corruption grants, the security that whistleblowers once expected is no longer a sure thing. NGOs and whistleblowers, once able to count on U.S. support, are now exposed to both financial insecurity and rising political risk.
Understanding ‘The Plan’
With the U.S. seemingly backing away from its leadership position as a corruption-fighter, other nations have a chance to seize the opportunity to continue this noble tradition. NWC Founder and Chairman of the Board Stephen M. Kohn detailed the pragmatic next steps for the international community in a publicly available article titled, A Reverse Marshall Plan for Anti-Corruption: Liberal Democracies Can Fill the Void Left by The Changes in U.S. Policies.
As detailed in the Reverse Marshall Plan, the current moment is not only a setback, but a chance for transformation. The global fight against corruption cannot be held hostage to the policy swings of one state—especially when 46 countries, including all major liberal democracies, have the tools and legal infrastructure to lead globally.
The Reverse Marshall Plan proposal is rooted in realism and hope. It calls for democracies—especially EU members, the United Kingdom, Canada, Australia, and Japan—to move from bystanders to leaders in anti-corruption enforcement.
“Instead of relying on the U.S. prosecutors,” Kohn notes in the Plan, nations that are members of the Organisation for Economic Co-operation and Development (OECD), “can rely upon each other, and should file cases under their own laws, thereby directly obtaining the billions of dollars in sanctions previously obtained by the United States and continuing effective transnational enforcement of the FCPA.”
Together, these countries host sophisticated legal systems, independent judiciary, and advanced anti-bribery laws modeled on the OECD Anti-Bribery Convention and the FCPA.
The Plan highlights how more than 70% of FCPA sanctions in the past decade have come from prosecutions against companies outside the U.S., with global whistleblowers driving most tips and law enforcement agencies in more than 60 countries cooperating in complex cases. As Kohn notes, these facts expose the profound, transnational reach of contemporary anti-corruption work—and the opportunity for other democracies to coordinate, pool resources, and enforce laws robustly in the absence of U.S. leadership.
Actionable Steps: Empowering Civic Participation and Global Cooperation
To fill the void and reinvigorate UNCAC, liberal democracies must:
- Defend and expand civil society space at CoSP11 and all UNCAC platforms, removing bureaucratic and political obstacles to NGO participation and providing meaningful input at all stages of anti-corruption reviews.
- Upgrade and harmonize enforcement by adopting and modernizing FCPA-style laws, implementing transparent whistleblower protections, and ensuring that all financial penalties are commensurate with international standards, like those established by the OECD, which encourages its member countries to issue sanctions when violations occur.
- Directly fund and protect NGOs by establishing pooled democracy-support funds, offering emergency legal protection to activists, and sharing best practices for resistance to state and corporate reprisals.
- Reinvest enforcement proceeds—such as fines won through anti-bribery cases—back into civic capacity-building, public education, and whistleblower defense funds, reversing the loss of former U.S. grants.
- Coordinate rapid response at the diplomatic and legal level, ensuring that civic actors facing intimidation have international recourse.
One of the key outcomes of CoSP10 was the CoSP Whistleblower Resolution (CAC/COSP/2023/Rev.1), and it was a bit of a double-edged sword. Though it addressed the crucial issue of safeguarding individuals who expose or report corruption and related offenses to competent authorities, any language on rewards in the final resolution was removed.
The Reverse Marshall Plan lays out strategies for the use of funds – in addition to compensating the whistleblower. And if true reform is to be instituted, Kohn said, financial rewards need to be reconsidered.
“Whistleblowers need to be incentivized to come forward and know that there is a light at the end of the tunnel for their bravery,” said Kohn, who was recently named to Forbes’ annual list of America’s Top Lawyers for the second consecutive year. “Their jobs and their livelihoods will be greatly impacted, and I’ve seen [clients] who have endured terrible economic burdens that have taken years to correct. Doing the right thing is important, but for a successful international plan to work, it must go further in the way of financial compensation.”
The Stakes and the Road Ahead
While U.S. withdrawal leaves a gap, it also delivers an imperative: anti-corruption must become a shared, resilient project of the world’s democracies. Strategies that center whistleblowers and civic voices are not just morally urgent—they are empirically proven to generate results, yields, and system-wide transparency.
During CoSP11, Kohn and NWC delegates will stress the need for enhancing the prosecutions of foreign bribery and money laundering. The goal is threefold:
(1) encourage states to implement best practice whistleblowing and anti-corruption laws,
(2) urge states to educate whistleblowers about their rights abroad,
(3) work with states through the Implementation Review Mechanism (IRM) to accomplish goals #1 and #2.
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“As negotiations continue, the takeaway is clear,” Kohn said. “It’s time for liberal democracies to ‘reverse’ the historic dynamic of U.S. dominance and instead build a transnational enforcement regime, with civil society not as a shadow partner but as a centerpiece. If the global fight against corruption is to succeed, new leaders and the world’s civic actors must unite now.”
Additional Resources
The decision to come forward is not one to be taken lightly, nor should selecting a whistleblower lawyer. NWC provides resources that can connect you with the right legal professional prior to taking any action.
Subscribe to the Sunday Read series for more CoSP11 coverage.
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This story was written by Justin Smulison, a professional writer, podcaster, and event host based in New York.
