Worldwide: Whistleblowing

Whistleblower programs are a critical component of strong governance and accountability. At MGO, we provide independent oversight and ethics hotline administration for a major transit agency.

The House Ways and Means Committee has unanimously approved legislation to reform the IRS Whistleblower Program, addressing critical structural weaknesses that have plagued the system for years.

A San Diego jury has awarded a former substance abuse counselor $105 million after finding she was terminated for reporting workplace harassment, a hidden camera, and patient safety violations.

On April 1, 2026, the Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (“NPRM”) to establish a formal whistleblower program under the Bank Secrecy Act (“BSA”). While much of the discussion has focused on what the proposed rule will do, the more fundamental question is why such a rule became necessary.

A recent Ninth Circuit decision highlights how private whistleblowers can drive significant False Claims Act litigation and settlements even when the federal government declines to intervene or actively seeks dismissal. The case examines the boundaries of attorney fee enhancements in FCA cases, particularly when counsel achieves unprecedented results without government support.

The U.S. Treasury Department unveiled its new plan to attack financial crimes, with a particular emphasis on those involving fraud against government healthcare plans.

On January 29, 2026, the Antitrust Division of the U.S. Department of Justice (“DOJ”) announced the first-ever $1 million reward to a whistleblower in an antitrust matter.

When an executive leader leaves their employer, negotiating a severance package can be a sensitive endeavor. If that executive is a potential whistleblower, the severance negotiations take on even greater importance.

In recent years, whistleblower protection laws have evolved significantly across both public and private sectors. Enhanced enforcement by agencies such as the Securities and Exchange Commission (SEC), Occupational Safety and Health Administration (OSHA), and the Consumer Financial Protection Bureau (CFPB) reflects a clear federal commitment to supporting individuals who report misconduct.