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SEC WHISTLEBLOWER PROGRAM

Whistleblower Awards

Make no mistake, the odds are stacked. The agency receives more than 20,000 tips, complaints and referrals each year, approximately 20% from the whistleblower office. At any one time, the SEC can only actively investigate about 2,000 cases. Each year, the SEC announces approximately 800 successful enforcement actions, about 20% of which involve monetary sanctions above $1 million – the statutory minimum for the whistleblower program.

We haven’t even touched on eligibility requirements.

So qualifying submissions and blockbuster cases are few and far between. But they do happen. For our clients, anyway.

Impacting Factors*

An SEC whistleblower award can range between 10-30% of the monetary sanctions collected in a qualifying enforcement action. Where the award falls is up to the agency’s discretion. Certain criteria may increase an award, such as the significance of the information provided by the whistleblower, the assistance provided by the whistleblower, the law enforcement interest in making an award and the participation of the whistleblower in internal reporting systems.

Both positive and negative factors are used to determine the award. Below are the factors, and how they appear to relate to the published awards.

In the 46 of 49 cases where information was disclosed...
Positive Factors
Signifigance of the Information Provided
100%
Assistance Provided
65%
Law Enforcement Interest
24%
Participation in Internal Compliance Systems
26%
Negative Factors
Culpability
2%
Unreasonable Reporting Delay
17%
Interference with Internal Compliance and Reporting Systems
2%
Examples of Whistleblower Awards
More in SEC Whistleblower Awards
Facts & Figures

Awards Denied

Whistleblower provided information and assistance that led to a successful enforcement action, involving overseas violations. The Commission noted that the whistleblower reported internally and provided extensive and ongoing cooperation during the investigation, including reviewing documents and providing sworn testimony.

Applicant 1 $1,800,000 [REDACTED]

[REDACTED]

  • Significance of the Information Provided
  • Assistance Provided
  • Law Enforcement Interest
  • Participation in Internal Compliance Systems

An overseas whistleblower provided information that led to a successful enforcement action.. The Commission emphasized the whistleblower's timely reporting, hard to detect violations, and inability to provide continuing assistance.

Applicant 1 $500,000 [REDACTED]

[REDACTED]

  • Significance of the Information Provided

Two whistleblowers provided information that resulted in an investigation and related successful enforcement action, involving violations that impacted retail investors. The Staff noted the whistleblowers tenancious internal reporting and assistance with the investigation. The Commission noted that the voluntary requirement had not been met, but they waived this procedural requirement because they believed it to be in the public interest.

Applicant 1 $1,500,000 [REDACTED]
Applicant 2 $1,500,000 [REDACTED]

[REDACTED]

  • Significance of the Information Provided
  • Assistance Provided
  • Participation in Internal Compliance Systems

Whistleblower provided information to his/her company, which triggered an investigation and subsequent reporting to the SEC and a related successful enforcement action. This is the first time a whistleblower has benefited from the 120 day internal reporting safe harbor.

Applicant 1 $4,500,000 [REDACTED]

[REDACTED]

  • Significance of the Information Provided
  • Participation in Internal Compliance Systems

Two whistleblowers provided high-quality information that assisted the SEC in bringing a successful enforcement action, efficiently. The Staff described them as providing "smoking gun" evidence and indispensable assistance. The Commission noted that whistleblower 1's award was reduced due to unreasonable delay.

Applicant 1 $13,000,000 [REDACTED]
Applicant 2 $37,000,000 [REDACTED]

[REDACTED]

  • Significance of the Information Provided
  • Assistance Provided
  • Unreasonable Reporting Delay
  • Interference with Internal Compliance and Reporting Systems

The whistleblower, a foreign national, provided information that caused an investigation to be open and assistance that led to a successful enforcement action.

Applicant 1 $4,000,000 [REDACTED]

[REDACTED]

  • Significance of the Information Provided
  • Assistance Provided

Whistleblower provided information and assistance that was critical to the overall success of the enforcement action. The Commission noted that the award was severely reduced because of unreasonable delay in reporting.

Applicant 1 $1,500,000 [REDACTED]

[REDACTED]

  • Significance of the Information Provided
  • Assistance Provided
  • Unreasonable Reporting Delay

Two whistleblowers provided specific and timely information to the Commission that led to a successful enforcement action. Whistleblower one was first to report, but the other whistleblower significantly contributed to the success of the case. The Commission noted that whistleblower 2's award was reduced because of unreasonable delay. Both whistleblowers were denied an award associated with a related CFTC action.

Applicant 1 $39,000,000 [REDACTED]
Applicant 2 $15,000,000 [REDACTED]

[REDACTED]

  • Significance of the Information Provided
  • Assistance Provided
  • Unreasonable Reporting Delay

The whistleblower, a former company insider, provided information that led to multiple successful enforcement actions. The Commission noted the award was reduced based upon the finding that he/she unreasonable delayed reporting.

Applicant 1 $2,100,000 [REDACTED]

[REDACTED]

  • Significance of the Information Provided
  • Assistance Provided
  • Unreasonable Reporting Delay

The whistleblower, a former company insider, provided information to another federal agency and later reported the possible securities violation to the Commission resulting in a successful enforcement action. This was the first whistleblower to use the Rule 21F-4(b)(7), which treats information provided to another federal information, as if reported directly to the SEC, if the whistleblower subsequently reports it to the Commission within 120 days.

Applicant 1 $2,200,000 [REDACTED]

[REDACTED]

  • Significance of the Information Provided

The Commission announced the highest ever whistleblower award to three whistleblowers who provided significant information that led to a successful enforcement action. Significantly, the Commission noted that awards were reduced because of delayed reporting.82000

Applicant 1 $49,000,000 [REDACTED]
Applicant 2 $33,000,000 [REDACTED]

[REDACTED]

  • Significance of the Information Provided
  • Assistance Provided
  • Unreasonable Reporting Delay

Whistileblower, a former company insider, reported a wide-spread, multi-year securities violation and provided assistance throughout the SEC's investigation. The Staff noted that whistleblower was foreign national. Significantly, the Commission noted that award was reduced somewhat because of delayed reported.

Applicant 1 $4,100,000 [REDACTED]

[REDACTED]

  • Significance of the Information Provided
  • Assistance Provided
  • Participation in Internal Compliance Systems

Two whistleblowers were granted awards. The first alerted the Staff to the particular misconduct that would become the focus of the Staff's investigation. The second provided additional significant information and ongoing cooperation. The Commission noted that the first whistleblower did not submit the information in the form required by Rule 21F-9(d), but waived the requirement due to special circumstances.

Applicant 1 $8,000,000 [REDACTED]
Applicant 2 $8,000,000 [REDACTED]

[REDACTED]

  • Significance of the Information Provided
  • Assistance Provided
  • Participation in Internal Compliance Systems

Whistleblower, a company outsider, provided the SEC with new information and substantial corroborating documentation of a securities law violation by a registered entity that impacted retail customers.

Applicant 1 $1,000,000 [REDACTED]

[REDACTED]

  • Significance of the Information Provided

A company insider reported a hard-to-detect violation of the securities laws, thereafter providing critical information that helped end the multi-year fraud. The SEC stated that millions of dollars were returned to harmed investors as a result of the ensuing investigation and enforcement action.

Applicant 1 $1,700,000 [REDACTED]

[REDACTED]

  • Significance of the Information Provided
  • Assistance Provided
  • Law Enforcement Interest
  • Culpability
  • Unreasonable Reporting Delay

Whistleblower was an employee of a domestic government agency who provided a timely tip and continued assistance, including testimony, that helped launch and accelerate an SEC investigation, leading to successful enforcement action..

Applicant 1 $2,500,000 [REDACTED]

[REDACTED]

  • Significance of the Information Provided
  • Assistance Provided

A company insider reported hard-to-detect violations of the securities laws to the SEC.

Applicant 1 $500,000 [REDACTED]

[REDACTED]

  • Significance of the Information Provided

Whistleblower provided the SEC with detailed and specific information about serious misconduct and provided additional assistance during the ensuing investigation. In particular, the whistleblower was commended for his or her industry-specific knowledge and expertise, which allowed the Commission to be more effective and efficient.

Applicant 1 $4,000,000 [REDACTED]

[REDACTED]

  • Significance of the Information Provided
  • Assistance Provided

The whistleblower provided information that led to a successful enforcement action. The award was subject to an off-set for the Claimant's culpability in connection with the securities law violations at issue in the Covered Action and the Claimant's unreasonable delay in reporting the wrongdoing to the Commission.

Applicant 1 Not Yet Determined 20% of sanctions awarded

[REDACTED]

  • Significance of the Information Provided
  • Culpability
  • Unreasonable Reporting Delay

whistleblowers that assisted the Staff after the investigation was opened.

Applicant 1 $4,000,000 [REDACTED]
Applicant 2 $1,500,000 [REDACTED]
Applicant 3 $1,500,000 [REDACTED]

[REDACTED]

  • Significance of the Information Provided
  • Assistance Provided

The whistleblower provided high-quality information that led to several successful SEC enforcement action against wrongdoers.

Applicant 1 $900,000 [REDACTED]

[REDACTED]

  • Significance of the Information Provided
  • Assistance Provided

The whistleblower provided information that led to a successful enforcement action. No additional information was provided.

Applicant 1 $3,500,000 [REDACTED]

[REDACTED]

  • Significance of the Information Provided

The whistleblower promptly came forward and provided valuable information that led to the successful SEC enforcement action. Notably, the whistleblower enabled the the Staff to stop the wrongdoers before they could squander almost any investor funds.

Applicant 1 $20,000,000 [REDACTED]

[REDACTED]

  • Significance of the Information Provided
  • Assistance Provided
  • Law Enforcement Interest

The whistleblower provided information that led to the successful SEC enforcement action. No additional information was disclosed.

Applicant 1 $4,000,000 [REDACTED]

[REDACTED]

  • None

The whistleblower, a company employee, provided the SEC with detailed information and assistance that led to the successful enforcement action. Without the whistleblower's courage, information and assistance, it would have been extremely difficult for law enforcement to discover this complex securities fraud on its own.

Applicant 1 $22,000,000 [REDACTED]

[REDACTED]

  • Significance of the Information Provided
  • Assistance Provided

The whistleblower, a former company employee, provided the SEC with detailed information and assistance that led to the successful enforcement action. The whistleblower enabled the Staff to converve time and resources and strengthen the evidence supporting the Commission's case.

Applicant 1 $17,000,000 [REDACTED]

[REDACTED]

  • Significance of the Information Provided
  • Assistance Provided
  • Law Enforcement Interest
  • Participation in Internal Compliance Systems

Whistleblowers provided information and assistance relating to possible securities violations to the SEC. This information led to a corporate accounting investigation. Their monetary award was increased due to the assistance provided to the Staff, after the Commission's investigation was opened.

Applicant 1 $225,000 [REDACTED]
Applicant 2 $225,000 [REDACTED]

[REDACTED]

  • Significance of the Information Provided
  • Assistance Provided

The whistleblower, a company insider, provided detailed information to the SEC that led to a successful enforcement. But for this tip, it would have been nearly impossible for the Commission to detect the securities violations.

Applicant 1 $6,000,000 [REDACTED]

[REDACTED]

  • Significance of the Information Provided

The whistleblower, a company employee, provided information and materials about possible securities violations that bolstered an ongoing investigation and related settlement negotiations. The Commission noted that the information significantly contributed to the success of the enforcement action.

Applicant 1 $3,500,000 [REDACTED]

[REDACTED]

  • Significance of the Information Provided
  • Assistance Provided

The whistleblower provided information that led to the successful SEC enforcement action. The award was subject to an offset for an unpaid Final Judgment against the whistleblower in a related, but different matter.

Applicant 1 $275,000 [REDACTED]

[REDACTED]

  • None

Three whistleblowers provided information that led to a successful enforcement action. The first whistleblower to report the possible violations received a substantially largest award than the whistleblowers that assisted the Staff after the investigation was underway.

Applicant 1 $1,800,000 [REDACTED]
Applicant 2 $65,000 [REDACTED]
Applicant 3 $65,000 [REDACTED]

[REDACTED]

  • Significance of the Information Provided
  • Assistance Provided

A whistleblower, who was an industry analyst, provided the SEC with a high-quality analysis about possible securities violations.

Applicant 1 $700,000 [REDACTED]

[REDACTED]

  • Significance of the Information Provided

The whistleblower, a current employee, provided information about ongoing securities violations by his/her company. The whistleblower helped to prevent further harm to a vulnerable investor community. Due to highly unusual circumstances, waived the requirement that the whistleblower submission be "in writing."

Applicant 1 $5,500,000 [REDACTED]

[REDACTED]

  • Significance of the Information Provided
  • Law Enforcement Interest

A whistleblower, who was a former investment firm employee, provided detailed information about possible securities violations and potentially knowledgeable individuals. The monetary award was reduced because the Commission deemed his/her delay in reporting unreasonable, even though the "delay was limited in duration," noting that the perpetrators obtained additional ill-gotten gains because of the whistleblowers failure to report until after he left the firm.

Applicant 1 $325,000 [REDACTED]

[REDACTED]

  • Significance of the Information Provided
  • Unreasonable Reporting Delay

Whistleblowers provided information that led to a successful enforcement action. No additional information was disclosed.

Applicant 1 Not Yet Determined 28% of sanctions awarded

[REDACTED]

  • None

Whistleblowers provided information that led to a successful enforcement action. No additional information was disclosed.

Applicant 1 Not Yet Determined 11% of sanctions awarded
Applicant 2 Not Yet Determined 9% of sanctions awarded

[REDACTED]

  • None

A whistleblower, who was a company insider, provided the SEC with specific and detailed information that comprehensively laid out the complex fraudulent scheme, which would have been very difficult for the Staff to detect otherwise. The monetary award was increased because his/her tip also led to other successful "related actions."

Applicant 1 $3,000,000 [REDACTED]

[REDACTED]

  • Significance of the Information Provided
  • Assistance Provided

SEC announces award to Labaton whistleblower in first retaliation case. After learning that the whistleblower reported possible securities violations to the Commission, the company immediately engaged in a series of retaliatory actions against the whistleblower, including removing him/her from his/her position, stripping the whistleblower of supervisory responsibilities, and otherwise marginalizing him/her.

Applicant 1 $600,000 30% of sanctions awarded

In the Matter of Paradigm Capital Management, Inc. and Candace King Weir, File No. 3-15930 (June 16, 2014)

  • Significance of the Information Provided
  • Assistance Provided
  • Law Enforcement Interest
  • Participation in Internal Compliance Systems

A whistleblower, who was a compliance professional, provided information and assistance to the SEC. He/she reported when there was a reasonable basis to believe that disclosure to the SEC was necessary to prevent imminent misconduct from causing substantial financial harm to the company or investors and senior management failed to take steps to stop it.

Applicant 1 $1,600,000 [REDACTED]

[REDACTED]

  • Significance of the Information Provided
  • Interference with Internal Compliance and Reporting Systems

First SEC whistleblower award to an officer of a public company. This Labaton whistleblower reported internally first, and only after his/her company didn't take appropriate action did he/she provide information and assistance to the Commission.

Applicant 1 $575,000 [REDACTED]

[REDACTED]

  • Significance of the Information Provided
  • Assistance Provided
  • Law Enforcement Interest
  • Participation in Internal Compliance Systems

A foreign whistleblower provided the SEC with key information about an ongoing fraud that would have been very difficult to detect without his/her assistance. The monetary award was reduced because the Commission deemed his/her delay in reporting unreasonable, noting that investors continued to suffer losses.

Applicant 1 $35,000,000 [REDACTED]

[REDACTED]

  • Significance of the Information Provided
  • Assistance Provided
  • Unreasonable Reporting Delay

A whistleblower, who worked as an audit or compliance professional, reported possible securities violations to the SEC, after his/her employer failed to take timely and appropriate action. Specifically, the whistleblower reported internally, including to his/her supervisor, yet no action was taken within 120 days of this initial report.

Applicant 1 $300,000 20% of sanctions awarded

[REDACTED]

  • Significance of the Information Provided
  • Participation in Internal Compliance Systems

After reporting internally, on several occasions and through several mechanisms, the whistleblower timely reported significant securities violations to the SEC. The whistleblower's efforts allowed the Staff's investigation to be more efficient. Due to special circumstances associated with the case, the Commission exercised its discretion to find that the whistleblower "voluntarily" provided the original information.

Applicant 1 $400,000 [REDACTED]

[REDACTED]

  • Significance of the Information Provided
  • Assistance Provided
  • Participation in Internal Compliance Systems

Whistleblower provided the SEC with information that led to a successful enforcement. No additional information has been disclosed.

Applicant 1 Not Yet Determined 15% of sanctions awarded
Applicant 2 Not Yet Determined 10% of sanctions awarded
Applicant 3 Not Yet Determined 5% of sanctions awarded

[REDACTED]

  • Significance of the Information Provided

Whistleblowers provided the SEC with information and assistance in a complex area of the securities market.

Applicant 1 $437,500 15% of sanctions awarded
Applicant 2 $437,500 15% of sanctions awarded

[REDACTED]

  • Significance of the Information Provided
  • Assistance Provided

Whistleblower provided valuable and timely information that allowed the SEC to stop an ongoing securities violations before additional investors were harmed. Due to collection problems, the award percentage was likely increased.

Applicant 1 $150,000 30% of sanctions awarded

[REDACTED]

  • Significance of the Information Provided
  • Assistance Provided
  • Law Enforcement Interest

Whistleblower provided information and assistance about ongoing securities violations that allowed the SEC to bring an enforcement action against the perpetrators within 6 months and recover substantial investor funds.

Applicant 1 $14,000,000 [REDACTED]

[REDACTED]

  • Significance of the Information Provided
  • Assistance Provided
  • Law Enforcement Interest

Whistleblowers provided the SEC and DOJ with information about an ongoing sham hedge fund. Part of the whistleblowers' monetary awards were based upon monies collected in a related criminal action.

Applicant 1 $125,000 5% of sanctions awarded
Applicant 2 $125,000 5% of sanctions awarded
Applicant 3 $125,000 5% of sanctions awarded

"United States v. Andrey C. Hicks, 1:11-cr-10407-PBS (D. Mass. 2011) (Related Action); SEC v. Andrey C. Hicks and Locust Offshore Management, LLC, 1:11-cv-11888-RGS (D. Mass. 2011) (SEC Action)"

  • Significance of the Information Provided
  • Assistance Provided

First SEC whistleblower award. The individual reported an ongoing multi-million dollar fraud. Due to collection problems, the award percentage was likely increased.

Applicant 1 $50,000 30% of sanctions awarded

[REDACTED]

  • Significance of the Information Provided
  • Assistance Provided
  • Law Enforcement Interest
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