By Vish Gain for AMLi
AT THE HEART of the difference between the whistleblowing directives of the United States and the European Union is a philosophical question that has divided economists and policymakers on both sides of the Atlantic: what motivates a whistleblower?
The US Securities and Exchange Commission’s whistleblower programme has served as an example for the EU’s own regional whistleblower regime which replaces the many national laws of member states, according to the WSJ. Organisations operating in Europe with more than 50 employees will be required to have ‘whistleblower hotlines’ to receive EU law violation reports, which includes money laundering.