Why Whistleblowers Get Paid in the U.S. but Not in Britain

In April, Barclays Plc said its chief executive officer, Jes Staley, was under investigation for trying to unmask an employee who’d raised ethical concerns about a senior staff member. Although the U.K. Financial Conduct Authority (FCA) says Staley wasn’t successful in identifying the so-called whistleblower, the incident raised questions about Britain’s scant protections for workers who aim to expose wrongdoing on the job—and highlights the difference between the British and American approaches.

In September the British government introduced rules that require companies to appoint a “whistleblower champion” and prohibit retaliation against employees who bypass internal reporting procedures and go straight to the regulator. Critics say a lack of financial incentives and the threat of being fired keep potential informants from speaking up. In the U.S., whistleblowing has been an important tool in the fight against white-collar crime since the Securities and Exchange Commission opened its Office of the Whistleblower in 2011.