Compliance officers are experiencing a wave of spurious reports to whistleblowing hotlines, with AI chatbots being used to generate lengthy, vague and implausible complaints. This especially affects higher profile companies, in particular those with significant scale, consumer-facing brands, or controversies around their operations. Some whistleblowers use AI in good faith to refine and structure their allegations in the most effective way. Unfortunately, this can result in lengthy complaints framed in legalistic language but lacking substance on the underlying issues, and sometimes actively undermining their severity.
Worse, a significant proportion of AI-assisted reports are spurious or even malicious, wasting the time of compliance officers and investigators, and distracting from genuine concerns. A small minority can reach the level of harassment, requiring a change in approach as they escalate. But any hasty attempt to respond forcefully to what internal stakeholders perceive as malicious reports could breach whistleblowing regulations aimed at protecting good faith reporters.
Based on our experience, in this article we set out the practical and technical steps compliance teams should consider when a reporter making spurious complaints shows signs of increasing escalation. We first consider what we define as ‘nuisance’ behaviour, such as repeated false complaints which could be characterised as harassment. We then explore the options that open up once a reporter crosses the line into malicious activity – such as threatening, defamatory or even criminal behaviour – to defend against this threat.
This article is part for Corporate Investigations in 2026 report which is available to download.
Dealing with the initial report
Based on both external regulations and a carefully developed whistleblowing policy, compliance teams have a duty to take seriously every report submitted via formal or informal whistleblowing channels. Even if a report contains multiple red flags, such as conspiratorial language or implausible exaggerations, initial triage should proceed as normal. Even genuine whistleblowing allegations can come couched in extreme and emotional language, especially if the whistleblower is already experiencing intense pressure or retaliation from immediate colleagues.
The process should include responding to the reporter promptly, requesting key details and clarifications from them, and carrying out an initial review to corroborate any sufficiently specific allegations. This might include confirming whether named employees, suppliers or customers actually exist, and whether the specific allegations are plausible in the context of the company’s operations. For example, when a client of ours received an allegation that their raw materials were being diverted from a factory to manufacture illegal recreational drugs, the team was quickly able to rule out this scenario by comparing lists of chemicals they procured with known drug precursor lists. The investigation continued, but was downgraded to a case of potential theft. The original whistleblower report looked like a precursor to an extortion attempt, but by not panicking and taking some early investigative steps, the client put themselves in the position to send a carefully-calibrated and defensible response, after which the reporter stopped communicating.
Compliance officers cannot give in to the temptation to skip this initial review and immediately dismiss a report due to the perception created by the presentation of the allegations. An overly dismissive approach exposes the company to criticism during audits or regulatory reviews of the compliance function. In the worst case scenario, if a specific allegation later turns out to be accurate, a hasty dismissal of the report could be characterised as a cover-up. Based on the findings of the initial review, any sufficiently specific and plausible allegations should result in an investigation, in line with the company’s policies.
Minimising contact
Some nuisance reporters escalate their behaviour by making repeated false allegations anonymously via formal and informal whistleblowing avenues. AI has driven a noticeable increase in the volume and length of these communications, by facilitating very rapid drafting and hallucinating superficially plausible details. These repeated communications can accelerate when not met with an immediate or public response to their allegations. To avoid overwhelming already stretched compliance teams, a simple workflow can be put in place to extract any new details and manage the wider impact.
Nuisance reporters sometimes begin directly emailing increasing numbers of employees, usually starting with the most senior, or even board members. If they are an insider with a grievance, they may have access to address books or mailing lists with large numbers of employees. Left unaddressed, this can drive speculation and affect morale among employees. Some thought should therefore be given to engaging senior stakeholders and addressing communications received by large numbers of staff, to reassure them without compromising the confidentiality of any ongoing investigation. Internal IT teams can also adjust settings on mailing lists intended for internal use to block all emails from external domains. If a nuisance reporter starts targeting a company’s clients, then it is critical that a communications strategy is put in place immediately to mitigate the commercial risk.
In dealing with a reporter escalating from whistleblower reports to nuisance communications, companies should continue to abide by their existing policies and templates for communications. Short, formulaic responses avoid giving nuisance reporters ammunition or motivation to escalate to a campaign of harassment, as well as respecting the confidentiality of any ongoing investigation. Once reasonable investigative steps have been carried out (and assuming the allegations cannot be substantiated), all contact can be cut. Certain steps can be taken to minimise the impact of repetitive communications, most importantly blocking known email accounts. However, a determined nuisance reporter can easily create new email accounts. Another method is to fingerprint the reporter’s spelling, choice of vocabulary and turns of phrase – and filter out communications on that basis. For example, S-RM worked on one matter where a nuisance reporter’s unique misspelling of the word ‘corrupt’ meant that their outreach to various of the client’s employees was easily blocked. Companies can work with their IT teams to tighten spam protection, as well as data loss prevention measures which make it harder for insiders with a grievance to exfiltrate sensitive documents for use in this type of harassment campaign.
As long as the allegations are only received internally, especially via dedicated whistleblower hotlines, caution is recommended regarding any proactive steps, for example to identify the reporter. Even though the investigation may have determined the reports to be completely unsubstantiated, and stakeholders perceive that they are being harassed, under whistleblower protection regulations any steps that could be characterised as retaliation might have negative legal and reputational consequences. In cross-border situations, even where the harassment is taking place in a jurisdiction with no whistleblower protections, the group may need to adhere to more rigorous standards than its subsidiaries.
This approach may feel frustrating, especially to any senior stakeholders who have been targeted. However, in this scenario the company has very limited ability to influence the behaviour of the nuisance reporter, beyond avoiding any action which could drive an escalation. Ideally, remaining passive will gradually let a nuisance reporter deescalate and disengage.
Crossing the line
When a malicious reporter crosses the line into possible lawbreaking, a range of options open up. The malicious activity could include blackmail, threats of physical violence, hacking or other theft of confidential information, or defamatory public statements. Legal advice is important to determine whether a nuisance reporter has turned into a truly malicious reporter whose actions justify proactive steps.
If a malicious reporter has improperly obtained, or even published, confidential information, a digital forensic investigation can determine the source of this data. Whether the information has been leaked by an insider, such as a disgruntled employee, or obtained by an external threat actor, understanding the method and extent of the data leakage is critical to ensure any vulnerabilities are patched and legal action can be taken if required. Alongside the digital forensic investigation, open source intelligence (‘OSINT’) research can support by looking into contact details and social media activity related to the malicious communications or posts to identify information that may assist with attribution.
If an insider has downloaded and shared sensitive documents, or is themselves the malicious reporter, digital forensic experts can gather evidence on corporate systems to demonstrate how, when and by whom the data was accessed and exfiltrated. This can be used to support defensible disciplinary action against any insider threat, as well as any future litigation.
Depending on confidentiality considerations, it may be helpful to make a police report locally, for example if any threats of violence are made, even if this is merely to create a paper trail. Beyond this, understanding who and where your threat actor is, as well as their communications, can also inform a threat assessment. A threat assessment analyses the motivation, capability, credibility, and intent of a threat actor, and can be used to fortify a company’s approach to the security of employees and facilities in response.
The culture question
Attempting to determine the motivation of an anonymous malicious reporter tends to be speculative and unproductive. The exception is when it becomes apparent that the source is an insider originally motivated by an arguably justified grievance. It may then be appropriate to take the opportunity to consider cultural issues highlighted by the malicious activity. Remediating cultural problems is not giving in to a malicious reporter’s blackmail, but protecting the business from future crises with the same root cause. In one situation we saw, the entrenchment of cliques within a company’s local subsidiary led to toxic behaviours in the workplace, and eventually a disgruntled employee exfiltrated confidential documents and shared them with former employees for use in a campaign of harassment. Left unchecked, the toxic aspects of the workplace culture risked alienating more employees and driving a cycle of weaponised false allegations.
