Largest SEC Whistleblower Awards to Date
Since 2012, the SEC has issued more than $800 million in SEC whistleblower awards, which includes a multi-million dollar payout to one of our clients. In 2020 alone, the SEC issued five of the top SEC whistleblower awards, totaling more than $241 million. The largest SEC whistleblower awards to date are:
- $114 million SEC whistleblower award (October 22, 2020);
- $50 million SEC whistleblower award (April 15, 2021);
- $50 million SEC whistleblower award (June 4, 2020);
- $50 million SEC whistleblower award (March 19, 2018);
- $39 million SEC whistleblower award (September 6, 2018);
- $37 million SEC whistleblower award (March 26, 2019);
- $33 million SEC whistleblower award (March 19, 2018);
- $30 million SEC whistleblower award (September 22, 2014);
- $28 million SEC whistleblower award (November 3, 2020);
- $27 million SEC whistleblower award (April 16, 2020); and
- $22 million SEC whistleblower award (September 30, 2020).
Under the SEC whistleblower-reward program, the SEC is required to issue awards to eligible whistleblowers who provide original information that leads to successful SEC enforcement actions with total monetary sanctions exceeding $1 million. A whistleblower may receive an award of between 10% and 30% of the total monetary sanctions collected. To date, more than $2.7 billion in monetary sanctions have been ordered against wrongdoers based on actionable information provided by whistleblowers.
Find out today if you might qualify for an SEC whistleblower award. Contact the Director of our SEC whistleblower practice at firstname.lastname@example.org or call our leading SEC whistleblower lawyers at (202) 930-5901 or (202) 262-8959.
Details of SEC Whistleblower Awards
The details of most payouts are not publicly available because many whistleblowers file anonymously through attorneys. An experienced SEC whistleblower attorney can skillfully guide whistleblowers through the process, maximizing the likelihood that their identity is not revealed to unauthorized parties. In addition, the SEC goes to great lengths to not reveal any information, including any details about the enforcement action, that could expose the whistleblower.
For example, when the SEC issued $30 million to an anonymous whistleblower, it did not identify the whistleblower, indicate where the whistleblower was from, or even disclose the case that the award was tied to. Andrew Ceresney, former director of the SEC’s enforcement division, simply said, “This whistleblower came to us with information about an ongoing fraud that would have been very difficult to detect.” The director also mentioned that the award could have been even bigger if the whistleblower had timelier reported the information to the SEC.
Not all whistleblowers wish to remain anonymous, however. On August 30, 2016, the SEC issued an award of more than $22 million to a former Monsanto executive. (Note: There are special eligibility rules for certain whistleblowers, such as executives, auditors, and compliance personnel.) According to the SEC’s press release, Monsanto lacked sufficient internal controls to account for millions of dollars in rebates. This control failure allowed the company to book a sizable amount of revenue without recognizing the costs associated with the rebates. This resulted in Monsanto’s materially misstating its consolidated earnings during a three-year period, ultimately leading to an $80 million penalty from the SEC. After the award was issued, the whistleblower spoke with reporters and revealed that he was a former executive at the company.
SEC Whistleblower Law Firm – Tier 1
If you are seeking representation in an SEC whistleblower award case, contact the Director of our SEC whistleblower practice at email@example.com or call our leading SEC whistleblower lawyers at (202) 930-5901 or (202) 262-8959. All inquiries are confidential. In conjunction with our courageous clients, we have helped the SEC halt multi-million dollar investment schemes, expose violations at large publicly traded companies and return funds to defrauded investors. Read our tips for SEC whistleblowers and Forbes column about the success of the SEC whistleblower program. We represent whistleblowers worldwide.
In 2018, Washingtonian magazine named two of our attorneys top whistleblower lawyers, and U.S. News and Best Lawyers® have named Zuckerman Law a Tier 1 firm in Litigation – Labor and Employment in the Washington DC metropolitan area. Click here to read reviews from clients that we have represented in whistleblower rewards and whistleblower retaliation matters.
Tracking SEC Whistleblower Awards
The table below identifies some of the largest awards that the SEC has provided to whistleblowers:
|Whistleblower Award||Date||Basis for Whistleblower Award|
|$114 million||October 22, 2020||On October 22, 2020, the SEC announced its largest-ever whistleblower award of $114 million to a whistleblower whose information and "substantial, ongoing assistance" led to the successful enforcement of SEC and related actions. The award consisted of an approximately $52 million award in connection with the SEC case and an approximately $62 million award arising out of the related actions by another agency.|
|$50 million||April 15, 2021||On April 15, 2021, the SEC announced a $50 million award to joint whistleblowers. The press release announcing the award stated, "The joint whistleblowers provided exemplary assistance to the SEC staff during the investigation, including meeting with staff numerous times and providing voluminous detailed documents. The information provided by these individuals resulted in the return of tens of millions of dollars to harmed investors."|
|$50 million||June 4, 2020||On June 4, 2020, the SEC announced its then largest-ever whistleblower award of $50 million to a whistleblower. In the press release announcing the award, the Chief of the SEC’s Office of the Whistleblower, Jane Norberg, stated: "This award is the largest individual whistleblower award announced by the SEC since the inception of the program, and brings the total awarded to whistleblowers by the SEC to over $500 million, including over $100 million in this fiscal year alone. Whistleblowers have proven to be a critical tool in the enforcement arsenal to combat fraud and protect investors."|
|$50 and $33 million||March 19, 2018||On March 19, 2018, the SEC announced an award of $50 million to two whistleblowers and an award of $33 million to another whistleblower. See the SEC's order determining the whistleblowers' award claims here.|
|$39 and $15 million||September 6, 2018||On September 6, 2018, the SEC announced its second-largest SEC whistleblower award to date of $39 million. According to the SEC's Press Release, the whistleblowers provided critical information and continued assistance that helped the SEC bring an important enforcement action.|
|$37 and $13 million||March 26, 2019||On March 26, 2019, the SEC announced its third-highest SEC whistleblower award to date of $37 million. Another whistleblower received a $13 million award in the same action, totaling $50 million in awards to the two whistleblowers.|
|$30 million||September 22, 2014||A foreign whistleblower came to the SEC with “information about an ongoing fraud that would have been very difficult to detect.”
This award underscores that non-US citizens are eligible whistleblowers in the SEC Whistleblower Program.
|$28 million||November 3, 2020||The SEC issued a $28 million award to a whistleblower who "provided significant information that aided the SEC in bringing a successful enforcement action." According to the press release announcing the award, the whistleblower "internally reported information that prompted the company to initiate an internal investigation, and saved the staff time and resources by providing testimony and identifying a key witness."
|$27 million||April 16, 2020||The SEC issued a $27 million award to a whistleblower who alerted the agency to misconduct occurring, in part, overseas. After providing the tip to the SEC, the whistleblower provided critical investigative leads that advanced the investigation and saved significant SEC resources. For more information, click here.|
|$22 million||August 30, 2016||A former financial executive at Monsanto exposed weaknesses in the company’s internal controls that failed to account for millions of dollars in rebates. Monsanto agreed to settle the allegations of accounting fraud for $80 million.
Importantly, external auditors, internal auditors, accountants and other compliance personnel may be eligible for awards under the SEC Whistleblower Program. Indeed, they are often best positioned to discover wrongdoing.
|$20 million||November 14, 2016||According to the SEC's order determining the whistleblower awards, three whistleblowers applied for awards related to the enforcement action. The SEC denied two of the whistleblowers' applications because they did not provide "original information," and issued the full $20 million award to one whistleblower.|
|$18 million||April 28, 2020||The SEC announced an award of more than $18 million to a whistleblower whose tip prompted an enforcement action that returned millions of dollars to retail investors.|
|$17 million||June 9, 2016||A company insider “substantially advanced the agency’s investigation and ultimate enforcement action.”
This award highlights that whistleblowers may receive an award if they provide original information regarding an open SEC investigation if it significantly contributes to the success of the action.
|$16 million||November 30, 2017||Two whistleblowers received awards of more than $8 million each for providing the SEC with critical information that led to a successful enforcement action.
This award demonstrates how whistleblowers can receive an increased award percentage for providing ongoing, extensive, and timely assistance to the SEC. As detailed in the SEC's order, the second whistleblower received the same $8 million award as the first whistleblower by providing additional significant information and ongoing assistance to the SEC that "enabled the Enforcement staff to more fully and quickly understand the misconduct and to assess the legal consequences... [which] saved a substantial amount of time and resources in the Investigation."
|$14 million||September 30, 2013||The whistleblower exposed a fraudulent offering that targeted foreign investors who sought to gain a legal pathway to citizenship through the EB-5 Immigrant Investor Program.|
|$9.2 million||February 23, 2021||The whistleblower provided significant information about an ongoing fraud to the SEC that enabled a large amount of money to be returned to investors harmed by the fraud. In addition, the whistleblower information led to successful related actions by the DOJ, one of which was a non-prosecution agreement (NPA) or deferred prosecution agreement (DPA). The award marks the first SEC whistleblower "related action" award based on a NPA or DPA with the DOJ since amendments to the SEC’s whistleblower program rules became effective on Dec. 7, 2020.|
|$7 million||January 23, 2017||Three whistleblowers split an award of more than $7 million after helping the SEC prosecute an investment scheme.
One whistleblower provided information that was the primary reason that the SEC opened an investigation. That whistleblower received a more than $4 million award. Two other whistleblowers jointly provided new information during the SEC’s investigation that significantly contributed to the success of the SEC’s enforcement action. Those two whistleblowers will split more than $3 million.
|$5.5 million||January 6, 2017||An anonymous whistleblower orally provided the SEC with critical information about ongoing securities fraud. Generally, the SEC requires that whistleblower provide information “in writing.” However, the SEC waived that requirement in this case due to “highly unusual circumstances” and awarded the whistleblower more than $5.5 million for the information.
This award marks the third time that the SEC has deemed it appropriate to waive a procedural requirement. The most recent exception occurred on July 27, 2017, when the SEC issued a $1.7 million whistleblower award to an insider who failed to comply with all of the whistleblower program's rules and had some culpability in the fraud. The former chief of the SEC whistleblower office said that these awards underscore the SEC’s discretionary authority to do what justice requires.
|$5 million||April 20, 2020||The SEC issued a $5 million award to a whistleblower who provided significant information that led to a successful enforcement action. According to the SEC, the whistleblower provided critical evidence of wrongdoing, which helped save time and resources in the SEC’s investigation, and the whistleblower suffered a unique hardship as a result of raising concerns internally.|
|$5 million||May 17,2016||A former company insider’s detailed tip led the agency to uncover securities violations that would have been nearly impossible for it to detect but for the whistleblower’s information. The SEC's press release noted that employees are often best positioned to witness wrongdoing.
|$4 million||April 25, 2017||The SEC issued the $4 million award to an anonymous whistleblower who provided information that led another governmental authority to a successful enforcement action resulting in significant monetary sanctions. This award highlights that SEC whistleblowers may be eligible for awards for "related actions."|
|$4 million||September 30, 2016||The SEC issued the award to an anonymous whistleblower for “alter[ing] the agency to a fraud.”
The lack of publicly available information about the anonymous whistleblower and the enforcement action underscores how serious the SEC is about protecting whistleblower's. Under the program, whistleblower may report anonymously through an SEC whistleblower attorney.
|$3.8 million||July 14, 2020||The SEC issued a $3.8 million award to a whistleblower that provided new information
during the course of an ongoing investigation into a fraudulent scheme. According to the order announcing the award, the information that the whistleblower provided “helped the Commission halt an ongoing fraud and return millions of dollars to harmed investors.”
|$3.5 million||May 13, 2016||The whistleblower “bolstered an ongoing investigation with additional evidence of wrongdoing” which helped the SEC during settlement discussions with the company.
This award underscores how whistleblowers may still receive an award even if the SEC already has an open investigation into a matter.
|$3.5 million||December 5, 2016||A whistleblower received an award of $3.5 million for providing original information to the SEC that led to a successful enforcement action. The press release states: "Whistleblowers do a tremendous service to the investing public and we will continue to reward those who come forward with valuable tips that help us bring successful cases against those who violate the securities laws."|
SEC Whistleblower Program
Click below to hear SEC whistleblower lawyer Matt Stock’s tips for SEC whistleblowers:
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SEC Whistleblower Protections
SEC whistleblowers are protected against retaliation under the anti-retaliation provisions of the Sarbanes-Oxley Act and the Dodd-Frank Act. We have substantial experience litigating whistleblower retaliation claims. If you have suffered retaliation for whistleblowing, call us today at (202) 262-8959.Protections for SEC Whistleblowers Post-Digital Realty (11-6-2020)
Top-Rated SEC Whistleblower Lawyers
We have assembled a team of leading whistleblower lawyers to provide top-notch representation to SEC whistleblowers. Recently Washingtonian magazine named two of our attorneys top whistleblower lawyers. U.S. News and Best Lawyers® have named Zuckerman Law a Tier 1 Law Firm in the Washington D.C. metropolitan area.
- Matt Stock is a Certified Public Accountant, Certified Fraud Examiner and former KPMG external auditor. As an auditor, Mr. Stock developed an expertise in financial statement analysis, internal controls testing and fraud recognition, and he uses his auditing experience to help whistleblowers investigate and disclose complex financial frauds to the government and obtain damages for retaliation. He is the lead author of SEC Whistleblower Program: Tips from SEC Whistleblower Attorneys to Maximize an SEC Whistleblower Award.
- Both Bachman and Zuckerman served in senior positions at the Office of Special Counsel, where they oversaw investigations of whistleblower retaliation claims and whistleblower disclosures, and enforced the Whistleblower Protection Act.
- Eric Bachman has substantial experience litigating precedent-setting employment cases. His wins include a $100 million settlement in a disparate impact Title VII class action and a $16 million class-action settlement against a major grocery chain. Having served as Special Litigation Counsel in the Civil Rights Division of the Department of Justice and as lead or co-counsel in numerous jury trials, Bachman is ready to go the distance to obtain the relief that you deserve.
- Jason Zuckerman was recognized by Washingtonian magazine as a “Top Whistleblower Lawyer” in 2017, 2015, 2009, and 2007 selected by his peers to be included in The Best Lawyers in America® in the category of employment law (2011-2017), and selected by his peers to be listed in SuperLawyers(2012 and 2015-2017) in the category of labor and employment law. Zuckerman is rated 10 out of 10 by Avvo, based largely on client reviews, and rated AV Preeminent® by Martindale-Hubbell based on peer reviews.
- Bachman and Zuckerman served on the Department of Labor’s Whistleblower Protection Advisory Committee, which makes recommendations to the Secretary of Labor to improve OSHA’s administration of federal whistleblower protections.
- The firm has published extensively on whistleblower rights and protections, and regularly speaks nationwide at seminars and continuing legal education conferences. We blog about new developments in whistleblower law at the Whistleblower Protection Blog.