Protecting Anti-Corruption Whistleblowers: Historical and Comparative Legal Aspects

The article explores the historical-legal and comparative legal problems of assessing the actions of persons who voluntarily report corruption (from Roman traditions and the Middle Ages to modern legislation in various countries). Using the examples of «actio popularis» and «qui tam», the analysis demonstrates how the idea of encouraging citizens to report offenses — while simultaneously shielding them from false accusations and unjust pressure — developed historically. The core question is whether current legal frameworks and public institutions adequately protect those who decide to expose corruption. Detailed attention is given to issues such as informants’ anonymity and potential rewards, alongside the dangers of abuse in the absence of proper oversight. The study also highlights international experience (e.g., in the United Kingdom, the United States, and several Asian countries) and examines the work of specialized agencies such as the Serious Fraud Office (SFO), which handles large-scale financial crime investigations. Such a system enhances trust in governmental institutions, helps curb corruption, and lays the groundwork for a more stable and equitable society.