Title page 1

Contents 3

Highlights 2

Letter 5

Background 7

Employment Practices That Create Trust Incentivize Disclosures, While Fear of Retaliation and Other Consequences May Disincentivize,... 11

Confidential or Anonymous Reporting Channels Allow Employees to Disclose with Confidence 11

Leaders Foster Employee Trust by Enforcing Discipline for Retaliators, Providing Anti-Retaliation Training, Monitoring Program Progress... 12

Fear of Retaliation, Burdensome Reporting, and Unclear Policies May Disincentivize Employee Disclosure 14

FTC and Other Agencies Cite Using Varied Mechanisms to Protect Disclosers, with Some Differences Attributable to Variations in Authority 16

Agencies Cite Using Confidentiality as a Mechanism for Protecting Discloser Identity 17

Some Agencies Take a Public Position on Non-disclosure Agreements 19

SEC Acts Against Restrictive Non-disclosure Agreements 21

OSHA's Whistleblower Protection Program Accepts Retaliation Complaints on Laws Administered by IRS, SEC and OSHA 21

Agencies Cite Challenges Including Securing Cooperation from Disclosers and Addressing NDAs, but Also Cite Monetary and Other Benefits 24

Agencies Identified Challenges Include Securing Cooperation, Contending with NDAs, and Processing and Coordinating Award Claims 24

Agency Officials Cite Benefits from Disclosures Including Recovered Funds, Increased Compliance, and More Efficient Investigations 28

Agency Comments 33

Appendix I: State-Level Protections for Whistleblowers 34

Appendix II: Selected Whistleblower Office Agency Eligibility Requirements and Claims Processes 36

Appendix III: GAO Contacts and Staff Acknowledgments 38

Tables 3

Table 1. Key Mechanisms Selected Federal Agencies Report Using to Protect Disclosers 16

Table 2. Number of Internal Revenue Service (IRS) Whistleblower Office Awards, by Fiscal Year, 2020 through 2024 18

Table 3. Number of Securities and Exchange Commission (SEC) Whistleblower Award Recipients, by Fiscal Year, 2020 through 2024 18

Table 4. Number of Positive Outcomes Resulting from Occupational Safety and Health Administration (OSHA) Retaliation Complaints,... 23

Table 5. Internal Revenue Service (IRS) Total Fund Recoveries Resulting from Whistleblower Information, Fiscal Years 2021-2024 (in millions) 29

Table 6. Federal Trade Commission (FTC), Bureau of Consumer Protection, Funds Returned to Consumers or Sent to U.S. Treasury as a Result... 31

Table 7. Federal Trade Commission (FTC), Bureau of Consumer Protection, 2024 Top 10 Identified Fraud Categories, by Number of Reports,... 32

Table 8. Whistleblower Eligibility Requirements at Selected Whistleblower Office Agencies 36

Table 9. Claims Process at Selected Federal Whistleblower Office Agencies 37