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National Whistleblower Center (NWC) is a global leader in whistleblower advocacy and continues to strengthen its international reputation for justice by maintaining a public presence. Through public engagement and appearances in the media and legal community, as well as hosting events, NWC highlights the achievements in whistleblower law and where improvements are still needed.
NWC fulfills its mission by extending its message globally, as Co-Founder and Chairman of the Board Stephen M. Kohn will represent NWC at the Organisation for Economic Co-operation and Development’s Global Anti-Corruption & Integrity Forum 2025 on March 25 in Paris, France. While there, Kohn will co-host a special discussion alongside the UN Global Compact’s Principles for Responsible Management Education (UNGC PRME) Working Group on Anti-Corruption and the Organisation for Economic Co-operation and Development (OECD).
In this Sunday Read, we will explore how thought leadership publications, as well as facilitating virtual and in-person events provide actionable takeaways for whistleblowers and lawyers alike, while also maintaining the relationship between NWC and its international counterparts amid geopolitical uncertainty.
Strengthening Whistleblower Protections and Fighting Corruption While in France
The fight against bribery and corruption continues, as does the need to ensure the protection and support of whistleblowers. This global challenge demands the attention of advocates and lawmakers; although many countries have established legal frameworks and protection mechanisms, significant gaps remain in making these systems efficient. Whistleblowers still encounter acts of retaliation, fragmented reporting channels, and uncertainty regarding whether their reports will reach appropriate authorities or result in meaningful action. Additionally, recent changes to United States’s anti-corruption enforcement policies have complicated the global fight against corruption, as foreign governments and whistleblower can no longer rely on the United States’s transnational legal framework for protection or enforcement.
To address the emerging crisis and discuss solutions, Kohn will be a featured panelist at a knowledge partner session of the OECD’s 2025 Global Anti-Corruption & Integrity Forum, “Whistleblower Protections Under Pressure: Addressing Barriers to Effectiveness.”
This session will discuss the urgent need for international whistleblower protection frameworks in light of recent changes to U.S priorities. The panel will examine how new frameworks can effectively allow whistleblowers to play a major role in the prosecuting foreign bribery and money laundering cases.
Kohn will be joined on the panel by:
Eliza Lockhart, Attorney and Research Fellow at the Centre for Finance and Security at the Royal United Services Institute (RUSI)
María de los Ángeles Estrada, Lawyer, leading Transparency, Anti-Corruption, and Digitalization Initiative in Mexico, whom you can read about in recent Sunday Read editions here and here.
Christopher Wylie, whistleblower, exposing massive privacy violations by Facebook and Cambridge Analytica
Eric Hylton, former Deputy of the IRS’s Criminal Investigation Division and head of International Operations.
Emin Huseynov, human rights defender, journalist, and whistleblower-advocate.
The conversation will also cover how to incentivize whistleblowers, ensuring they are motivated and protected when speaking out. Lockhart’s presence is particularly noteworthy, as she co-authored RUSI’s recent report on whistleblower awards which underscored the need for the recently announced whistleblower award framework in the U.K. modeled on U.S. programs.
“The UK has now modeled a tax whistleblower and reporting system on this highly successful framework,” Kohn recently told Whistleblower Network News. “It is a major step forward for tax accountability and the ability to hold large banks and millionaires accountable to honest taxpayers.”
Rallying International Participation During the FCPA Pause in the U.S.
Ahead of his presence at the OECD’s 2025 Global Anti-Corruption & Integrity Forum, Kohn has been contributing articles and essays based on his research regarding the state of U.S whistleblower laws, in particular the Foreign Corrupt Practices Act (FCPA).
Enacted by Congress in 1977 with several subsequent updates to include whistleblower protections, the FCPA targets bribery of foreign government officials by publicly traded corporations or U.S. persons. It is the most powerful and effective transnational anticorruption law in the world.
However, on Feb. 10, 2025, President Trump issued an executive order to pause enforcing the FCPA to “advance American economic and national security by eliminating excessive barriers to American commerce abroad.”
Critics of the order have noted that the pause will open the floodgates for widespread bribery and reduced accountability and consequences.
“This is a decades-old line of attack against the FCPA and one that is increasingly outdated as the U.S. has radically shifted its enforcement priorities towards foreign companies,” Kohn wrote in a recent article published by the NYU Compliance and Enforcement Blog. Entitled, “Crippling the FCPA is Bad Business for the U.S.”Kohn discussed how the FCPA protects American competitiveness and produces research demonstrating how FCPA enforcements primarily target foreign companies.
“The power of the FCPA has become its transnational application: the U.S. is able to crack down on both U.S. and foreign companies paying bribes overseas, protecting American competitiveness and the integrity of international markets,” he wrote. “When foreign companies obtain business through bribes and other corrupt means, it harms American businesses who are competing in that marketplace.”
Kohn also authored and submitted a professional report to the Social Science Research Network (SSRN), entitled, A Reverse Marshall Plan for Anti-Corruption: Liberal Democracies Can Fill the Void Left by The Changes in U.S. Policies. The concepts and suggestions detailed in this report lay out steps which democracies should follow in order to implement a “Reverse Marshall Plan.” The steps are based on the successes of the OECD’s Anti-Bribery Convention and the growing international acceptance of highly effective detection and enforcement tactics used by U.S. prosecutors under the FCPA. This paper will also be used to guide the discussion during NWC’s side event during the OECD’s 2025 Global Anti-Corruption & Integrity Forum.
Additionally, Kohn amplified his position on the need for FCPA enforcement during a recent episode of theWhistleblower Network News podcast, Whistleblower of the Week.
Hosted by two-time FBI whistleblower Jane Turner, the dialogue centered on developments in U.S enforcement of the FCPA, Kohn’s recent research and strategies for the U.S. and allies to move forward.
“[Countries]… in the European Union, Great Britain as well as Canada, Japan and South Korea all have Foreign Corrupt Practice Act laws, all of which can be activated and […] can be enhanced easily to include Dodd-Frank Act protections for the whistleblowers,” Kohn said on the podcast. Kohn added that using the U.S. as a model or template is the optimal strategy, especially since it has the endorsement of the OECD, whose auditors are not U.S. citizens and unbiased.
“As these countries engage,” he noted, “the transnational scope of fighting bribery will increase, and at the end of the day there will be actually better enforcement.”
Breaking News
In a major development for international anti-corruption efforts, the U.K Serious Fraud Office, France’s Parquet National Financier (PNF) and the Office of the Attorney General of Switzerland (OAG) announced a new International Anti-Corruption Prosecutorial Taskforce to collaborate on the enforcement of anti-bribery laws on March 20th. The breakthrough decision signals the shift in international anti-corruption leadership that Kohn and the National Whistleblower Center have called for.
Commenting on the decision, Kohn stated: “Given the transnational nature of anti-corruption enforcement, and the wide-reaching jurisdiction of the UK, France, and Switzerland, anti-bribery enforcement can not only be maintained, but it can even expand, despite the United States’ shifting policy. […] At the same time, the U.S. will lose out on billions of dollars in sanctions which they currently collect from their prior successful efforts.”
Resources for Whistleblowers
Visit the NWC resources to learn more about the Foreign Corrupt Practices Act (FCPA) and Dodd-Frank’s lasting impact.
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.
Support NWC
NWC fights to bolster whistleblower programs and raise awareness about the value of whistleblowers. As a 501(c)(3) non-profit our work is made possible with the support of our generous donors. Please consider donating $100 today to help us continue to educate the public about whistleblower experiences and the role whistleblowers play in putting an end to fraud and money laundering. Donors of $100 or more will receive a copy of Rules for Whistleblowers: A Handbook for Doing What’s Right.
This story was written by Justin Smulison, a professional writer, podcaster, and event host based in New York.
