Whistleblower Rewards for Reporting Wrongdoing
A whistleblower reward is a monetary incentive offered by the government to individuals for exposing certain wrongdoing. Federal laws require the government to reward whistleblowers with a percentage of the money that it recovers as a result of their tip. Whistleblowers may receive up to 30% of the total monetary recovery as a reward.
In the United States, there are four main whistleblower reward programs:
- SEC Whistleblower Reward Program: whistleblower rewards for reporting violations of the federal securities laws.
- The largest SEC whistleblower reward to date is $114 million.
- CFTC Whistleblower Reward Program: whistleblower rewards for reporting violations of the Commodity Exchange Act.
- The largest CFTC whistleblower reward to date is $45 million.
- IRS Whistleblower Reward Program: whistleblower rewards for reporting tax fraud or underpayments.
- The largest IRS whistleblower reward to date is $104 million.
- False Claims Act / Qui Tam Lawsuits: whistleblower rewards for reporting fraud against the government.
- The largest qui tam whistleblower reward to date is $250 million.
- Anti-Money Laundering Whistleblower Reward Program: whistleblower rewards for reporting money laundering.
Importantly, each whistleblower program has different rules and procedures for recovering a reward and whistleblowers are protected against retaliation. Whistleblowers should consult with an experienced whistleblower attorney to determine if their claim qualifies for a reward under one of these programs.
Top-Rated SEC Whistleblower Law Firm
SEC Whistleblower Reward Program
Under the SEC Whistleblower Reward Program, the SEC will issue awards to whistleblowers who provide original information that leads to enforcement actions with total monetary sanctions (penalties, disgorgement, and interest) in excess of $1 million. A whistleblower may receive an award of between 10% to 30% of the monetary sanctions collected.
Since 2012, the SEC has issued more than $700 million in awards to whistleblowers. The largest SEC whistleblower awards to date are $114 million, $50 million, $50 million, $39 million and $37 million.
The program allows whistleblowers to submit anonymous tips to the SEC if represented by an attorney. Whistleblowers are also afforded substantial protection against retaliation. If you are seeking representation in an SEC whistleblower reward case, click here, or call us at 202-930-5901 to schedule a free, confidential consultation.
The most common tips to the SEC Office of the Whistleblower involve:
- Accounting fraud;
- Investment and securities fraud;
- Insider trading;
- Foreign bribery and other FCPA violations;
- EB-5 investment fraud;
- Manipulation of a security’s price or volume;
- Fraudulent securities offerings and Ponzi schemes;
- Hedge fund fraud;
- Unregistered securities offerings;
- Investment adviser fraud;
- Broker-dealer anti-money laundering program violations;
- False or misleading statements about a company or investment;
- Inadequate internal controls;
- Deceptive non-GAAP financials;
- Improper revenue recognition;
- Violations of auditor independence rules;
- Misleading or incomplete cybersecurity disclosures; and
- Blockchain and cryptocurrency fraud.
To learn more about the SEC Whistleblower Program, download Zuckerman Law’s eBook SEC Whistleblower Program: Tips from SEC Whistleblower Attorneys to Maximize an SEC Whistleblower Award. Also, click below to hear SEC whistleblower lawyer Matt Stock’s tips for SEC whistleblowers:
As discussed in our articles, the SEC whistleblower program has become a very effective enforcement tool for the SEC. But very few whistleblowers have received awards, which underscores the importance of having experienced counsel represent a whistleblower effectively at the SEC.
- MarketWatch: More than 33,000 tips, $2.5 billion in financial remedies and $500 million in awards to investors — the SEC’s whistleblower program turns 10 years old today
- Going Concern: Here Are 6 Reasons Why the SEC Whistleblower Program Is Successful
- National Law Review: 5 Ways that Experienced SEC Whistleblower Law Firms Can Effectively Advocate for Whistleblowers
- D&O Diary: How the SEC Whistleblower Program Has Changed Corporate Compliance and SEC Enforcement
- Forbes: One Billion Reasons Why The SEC Whistleblower-Reward Program Is Effective
SEC Whistleblower Rewards
The table below identifies some of the largest SEC whistleblowers rewards:
|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||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.
Recently, there has been rise in EB-5 investment fraud. Click here to read more about how to report EB-5 fraud and earn an award.
|$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."|
CFTC Whistleblower Reward Program
Under the CFTC Whistleblower Reward Program, the CFTC will issue awards to whistleblowers who provide original information about violations of the Commodity Exchange Act that leads to enforcement actions with total monetary sanctions in excess of $1 million. A whistleblower may receive an award of between 10% to 30% of the monetary sanctions collected. In 2018, a whistleblower received a reward of more than $30 million for exposing that JPMorgan Chase & Co. did not properly disclose conflicts of interest to clients.
CFTC Whistleblower Rewards
The table below identifies some of the largest CFTC whistleblowers rewards:
|Whistleblower Award||Date||Basis for Whistleblower Award|
|$45 million||August 2, 2018||On August 2, 2018, the CFTC announced a $45 million award to multiple whistleblowers. Reports indicate the award was related to ISDAFIX manipulation enforcement actions.|
|$30 million||July 12, 2018||On July 12, 2018, the CFTC announced its largest-ever whistleblower award given to an individual. The whistleblower exposed that JP Morgan did not properly disclose conflicts of interests to clients. Find the order here.|
|$10 million||March 28, 2016||On April 4, 2016, the CFTC announced a $10 million award given to an individual. The whistleblower provided “valuable information” regarding violations of the Commodity Exchange Act. Find the order here.|
|$7 million||September 27, 2019||On September 27, 2019, the CFTC issued a $7 million award to a whistleblower. CFTC Director of Enforcement James McDonald stated in the Press Release: “Forty percent of our investigations now involve whistleblowers. We expect that number to increase as the CFTC continues to expand its whistleblower program.” Find the order here.|
|$6 million||June 9, 2020||On June 9, 2020, the CFTC issued a $6 million award to a whistleblower who voluntarily provided original information that led the CFTC to bring a successful enforcement action. According to the Press Release announcing the award, the CFTC opened its investigation upon receiving the whistleblower’s information, which was specific, credible and timely.|
|$2.5 million||June 24, 2019||On July 24, 2019, the CFTC issued a $2.5 million CFTC whistleblower award to an individual. The award was reduced because of the whistleblower’s delay in reporting. Director McDonald said the delay was “unreasonable” and the whistleblower could have received a larger award had this person not waited. Find the order here.|
|$2 million||July 1, 2019||On July 1, 2019, the CFTC issued a $2 million CFTC whistleblower award to two whistleblowers. The whistleblowers provided multiple interviews and documents that were “highly informative” and provided the agency “with significant information” that prompted the CFTC to open an investigation. The whistleblowers also reported the violations to another organization that conducted a separate investigation and shared its findings with the CFTC. Find the order here.|
|$2 million||March 4, 2019||On March 4, 2019, the CFTC announced an award of over $2 million to a whistleblower. The whistleblower conducted an "independent analysis" of market data, which aided greatly in the CFTC’s investigation. The whistleblower was not an insider. The order is here.|
|$1.5 million||May 6, 2019||On May 6, 2019, the CFTC announced a $1.5 million award to a whistleblower who tried to report it internally first. The CFTC granted the reward to the whistleblower for both a CFTC action and a related action brought by another federal regulator. Find the order here.|
|$290,000||September 29, 2015||On September 29, 2015, the CFTC announced an award of $290,000 to a whistleblower. Two applicants applied for the award, but the CFTC only awarded one of the whistleblowers because the “the information provided by the second applicant did not lead to a successful enforcement . . . action.”|
|$240,000||May 20, 2014||On May 20, 2014, the CFTC announced its first-ever whistleblower award of $240,000. The then-acting director of the CFTC reported that the whistleblower provided “specific, timely and credible information” that led to a successful investigation.|
IRS Whistleblower Reward Program
Under the IRS Whistleblower Reward Program, the IRS provides whistleblower rewards to individuals of 15% to 30% of proceeds collected from tax fraud or tax underpayments if:
- the whistleblower provides a tip that the IRS decides to take action on (a whistleblower cannot force the IRS to act on a tip);
- the amount in dispute (the tax underpayment, including interest and penalties) exceeds $2 million (if the taxpayer is an individual, his or her gross income must exceed $200,000 for at least one of the tax years in question); and
- the IRS collects tax underpayments resulting from the action (including any related actions).
The largest IRS whistleblower reward to date is $104 million, which was issued to Bradley Birkenfeld after he blew the whistle on UBS for helping wealthy Americans hide their assets and evade taxes.
False Claims Act / Qui Tam Whistleblower
The False Claims Act contains a qui tam provision allowing whistleblowers, or qui tam “relators,” to bring suits on behalf of the United States against wrongdoers who are defrauding the government. Whistleblowers are eligible to receive 15% to 30% of monetary recoveries. Whistleblowers are also afforded substantial protection against retaliation under the Act.
In fiscal year 2017 alone, qui tam actions brought by whistleblowers resulted in $3.4 billion in settlements and judgments, and the government paid $392 million in whistleblower awards to False Claims Act whistleblowers. To learn about False Claims Act whistleblower protection, see our FCA whistleblower retaliation FAQ.
Anti-Retaliation Laws Protecting Whistleblowers
Whistleblowers disclosing fraud to the government or to their employers are protected against retaliation under federal and state laws, including the following:
- Sarbanes-Oxley Act (protecting whistleblower disclosures about violations of SEC rules and regulations; violations of federal laws related to fraud against shareholders; or mail, wire, bank, or securities fraud). Download our free ebook, Sarbanes-Oxley Whistleblower Protection: Robust Protection for Corporate Whistleblowers.
- Taxpayer First Act (protecting whistleblowing about tax fraud or tax underpayment)
- Dodd-Frank Act (protecting whistleblowing to the SEC and CFTC)
- False Claims Act and NDAA (protecting whistleblowers working for federal contractors)
- Consumer Financial Protection Act (protecting disclosures concerning consumer financial protection)
Click here to learn more about anti-retaliation protections for SEC whistleblowers under the Dodd-Frank Act and Sarbanes-Oxley Act. If you have suffered retaliation for whistleblowing, call our experienced whistleblower protection lawyers today at 202-262-8959.
Top-Rated 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 firm in Litigation – Labor and Employment in the Washington DC 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.
- 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.
- Jason Zuckerman was recognized by Washingtonian magazine as a “Top Whistleblower Lawyer” in 2018, 2017, 2015, 2009, and 2007 selected by his peers to be included in The Best Lawyers in America® in the category of employment law (2011-2020), and selected by his peers to be listed in SuperLawyers (2012 and 2015-2020) in the category of labor and employment law. 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.