Whistleblowing and Economic Crime

Our work examines domestic and international whistleblowing frameworks, particularly the role of financial rewards, to examine how whistleblowers can be better recognised, protected and utilised as a source of intelligence in the fight against economic crime.

Lone voices: More can be done to support people that speak out against sanctions avoidance. Image: Freshidea / Adobe stock

Whistleblowers can play a critical role in detecting and disrupting economic crime, providing insider intelligence that may otherwise be inaccessible to law enforcement and regulatory authorities. Our research examines how whistleblowing frameworks, particularly the use of financial rewards, can improve the detection, investigation and prosecution of economic crime. Drawing on international experience, we assess the effectiveness and design of whistleblower reward programmes and their potential application in the UK.

Lone voices: More can be done to support people that speak out against sanctions avoidance. Image: Freshidea / Adobe stock

Policy Debate and Impact

In December 2024, CFS Senior Research Fellow, Eliza Lockhart, authored a research paper examining whistleblower reward programmes in the US and Canada and the lessons for the UK. The research was published and funded by the Serious Organised Crime and Anti-Corruption Evidence (SOC ACE) Research Programme, which is funded by the UK Foreign, Commonwealth & Development Office (FCDO). Upon its publication, the paper was profiled in the Financial Times and the then-Director of the Serious Fraud Office, Nick Ephgrave, spoke at the launch event.

The paper has contributed to a significant shift in the UK policy debate on financially rewarding whistleblowers. It was cited in the UK government's UK Anti-Corruption Strategy 2025 and Jonathan Fisher KC's Independent Review of Disclosure and Fraud Offences in support of introducing financial rewards for economic crime whistleblowers. This represents a notable transformation from the longstanding opposition to financially rewarding whistleblowers among UK policymakers, regulators, the legal sector and civil society organisations

Since the paper was published, the Financial Conduct Authority has reconsidered its opposition to financial incentives; HMRC has introduced a strengthened whistleblower reward scheme drawing on the US and Canada models; and the Serious Fraud Office has advocated for the introduction of its own economic crime whistleblower reward scheme. In October 2026, the UK government launched a public consultation on the design of the proposed SFO scheme, marking an important step towards the potential introduction of financial incentives for reporting economic crime in the UK.

Aims and Objectives

Our research aims to strengthen the role of whistleblowers in tackling economic crime by identifying effective regulatory and enforcement approaches, drawing on international evidence and experience.

Our objectives are to:

Examine international best practice: Assess the effectiveness of whistleblowing frameworks and financial reward programmes across jurisdictions to identify lessons for policymakers, regulators and law enforcement authorities.
Identify effective regulatory approaches: Analyse the legal, operational and institutional conditions needed for effective whistleblowing programmes, including whistleblower reward programme design, intelligence-handling capabilities and enforcement mechanisms.
Inform policy development: Provide evidence-based recommendations to strengthen UK and international whistleblowing frameworks and support the effective use of whistleblower intelligence in combating economic crime