APPS was enacted in 1980 as part of MARPOL, an international convention on limiting pollution and dumping, and the unique structure of maritime law allows for more potential whistleblower cases. APPS applies to both U.S.-flagged ships and foreign vessels in U.S. waters, or ships at a port under U.S. jurisdictions. The whistleblowers do not need to be U.S. nationals. Recent APPS whistleblower settlements reflect the international potential of the cases. In 2014, the Italian shipping company Carbofin settled allegations of APPS violations for $2.15 million. On June 20, 2017, Egyptian Tanker Company and Singaporean shipping company Thome Ship Management settled allegations of intentionally polluting the Gulf of Mexico for $1.9 million. The Department of Justice writes that $200,000,000 of APPS penalties have been imposed in the last ten years.
The APPS text is available online, including on the EPA website. Proof that a company violated the APPS regulations, combined with demonstrated awareness of the regulations and intent to violate them, would make for a compelling whistleblower case.

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