The Lure of U.S. Whistleblower Rewards Pushes HMRC to Launch its own Strengthened Reward Program
Do not pass Go. Do not collect £200. Proceed directly to Washington. Until recently, that, in Monopoly terms, is what the UK’s would-be fraud whistleblowers have been doing. On February 13, 2024, in his first public speech as Director of the Serious Fraud Office, Nick Ephgrave said that since 2012 some 700 UK nationals had “gone to America to whistleblow,” bypassing the UK regulators, because they saw no incentive to do so at home. In his July 14, 2026 report “Fraud in the Digital Age,” Jonathan Fisher KC counts 774 UK individuals making protected disclosures to four US reward regulators (the IRS, SEC, CFTC and FinCEN) between 2012 and 2023.
On the other side of the pond, data from the SEC also supports this trend of UK whistleblowers coming to America. In its annual reports to Congress, the SEC’s Office of the Whistleblower shows the UK among the top foreign sources of whistleblower tips year after year. The SEC listed the UK among the top foreign sources in FY2013 (UK 66 tips, Canada 62, China 52), FY2014 (UK 70) and FY2015 (UK 72). In FY2016 Canada edged ahead, 68 tips to the UK’s 63. The UK has held that runner-up spot since FY2018, briefly beating Canada in FY2017. In FY2025, the top foreign sources were Canada, the UK, Italy, Germany and China. That is thirteen consecutive reports with the UK in the top three, never mind the top five.
Data from the IRS tells the same story. Its FY2023 report was the first to include a global breakout of whistleblowers by continent. Europe, which includes the UK, was the largest source of whistleblowers outside North America that year and in FY2024. That count went from 65 in FY2023 to 157 in FY2024. Europe was 73% of the IRS’s non-North American whistleblowers in FY2023 and 83% in FY2024.
Why are these UK whistleblowers coming to the US? Because the United States is incentivizing them. Compare a record $279 million SEC award to a single whistleblower, or $255 million paid to 47 SEC whistleblowers in FY2024 to HMRC’s previous discretionary scheme that reportedly paid all informants a combined £978,256 in 2023/24, then £852,438 in 2024/25.1
Then, late last year, seeking to stem the brain drain of UK whistleblowers headed to the US, HMRC fought back with a strengthened reward program of its own. Effective November 26, 2025, its Strengthened Reward Scheme pays 15% to 30% of tax collected, with no cap, where a tip leads to recovery of at least £1.5 million. The scheme is a homegrown answer to the magnetic effect of the American whistleblower programs.
This summer, there was further evidence of the tide in the UK turning further toward incentivizing whistleblowers. Ipsos polling commissioned for the Fisher review found some 70% of the UK public favor paying rewards to whistleblowers.
Whether HMRC’s Strengthened Reward Scheme changes where UK whistleblowers report is a number we’re watching going forward. As of mid-August, eight and a half months following the program’s launch, there were hopeful signs. At the Countering Financial Crime Conference organized by the Isle of Man’s Financial Services Authority, HMRC’s Gary Forbes reported “a good pipeline of cases” with “excellent engagement both domestically and internationally.”
By Mary Inman, Partner at Whistleblower Partners LLP
1 £978,256 ($1,293,980 at today’s exchange rate) and £852,438 ($ 1,127,560 at today’s exchange rate).
