Article | June 30, 2026
FCPA Enforcement: Where the Bribery Actually Happened
FCPA enforcement trends analyzed by geography. Discover where bribery risk is concentrated and how it impacts global compliance, investigations and risk management.
April 29, 2025
Secretariat’s Norman Harrison and Ben Boorer, together with Taylor Wessing attorneys Natasha Zahid and Mohammed Tartir, dive into the latest whistleblower issues and trends across the US, Europe, and the Middle East in their article, “When the Whistle Blows.” Read the full briefing to stay ahead of the curve.
Whistleblowing frameworks worldwide are further converging on a shared imperative of protecting and, in some cases, incentivizing those who report corporate misconduct. The United States still leads on payment of monetary rewards, but shifting enforcement priorities under the new administration, including a pause on FCPA enforcement and a constitutional challenge to qui tam suits, has created new uncertainty.
Europe is codifying protections first and debating incentives second. The EU Directive now obliges every organization with 50‑plus workers to maintain safe internal channels and anti‑retaliation measures, and the UK Serious Fraud Office is preparing the country’s first reward scheme to supplement tribunal remedies. Together, these moves mark a pivot from after‑the‑fact litigation to proactive disclosure.
Regulators in the Middle East are moving swiftly to match this trend. The Abu Dhabi Global Market’s 2024 rules require anonymous reporting and non‑retaliation regulations to be in place by May 2025, while Saudi Arabia’s 2024 Law pairs strict whistleblower confidentiality protections with rewards of up to five percent of recovered assets. For multinationals, the message is clear: embed credible, well‑publicized whistleblower channels now or risk escalating financial, legal and reputational fallout as global enforcement tightens.
If you would like to discuss any of the issues raised in this article, please reach out to Norman Harrison or Ben Boorer.
FCPA Enforcement: Where the Bribery Actually Happened
FCPA enforcement trends analyzed by geography. Discover where bribery risk is concentrated and how it impacts global compliance, investigations and risk management.
Secretariat is pleased to share that 56 of our experts have been recognized in the Lexology Index 2026 Construction report for their outstanding work on complex construction disputes and claims around the world. With 12 experts named as Global Elite Thought Leaders—the report’s most exclusive ranking, achieved by only 5% of listed professionals—Secretariat has earned the No. 1 spot in this category for the second year in a row among more than 750 ranked firms.
Eric Poer, a Managing Director in Secretariat’s Global Investigations & Disputes practice, was retained by the U.S. Securities and Exchange Commission (SEC) to serve as their forensic accounting expert in a high-profile securities fraud dispute.