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 $50 million.
- CFTC Whistleblower Reward Program: whistleblower rewards for reporting violations of the Commodity Exchange Act.
- The largest CFTC whistleblower reward to date is $30 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.
Importantly, each whistleblower program has different rules and procedures for recovering a reward. Whistleblowers should consult with an experienced whistleblower attorney to determine if their claim qualifies for a reward under one of the programs. For more information about whistleblower rewards and bounties, contact leading whistleblower law firm Zuckerman Law at 202-262-8959 or email us at firstname.lastname@example.org.
Tier 1 Law Firm Representing Whistleblowers at the SEC
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. The largest awards to date are $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 a SEC whistleblower reward case, click here, or call us at 202-262-8959 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.
The table below identifies some of the largest SEC whistleblowers rewards:
|Whistleblower Award||Date||Basis for Whistleblower Award|
|$50 and $33 million||March 19, 2018||On March 19, 2018, the SEC announced its largest-ever whistleblower awards, with two whistleblowers sharing a nearly $50 million award and a third whistleblower receiving more than $33 million. |
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.
|$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.|
|$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||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 (not the SEC) to a successful enforcement action resulting in significant monetary sanctions. |
This award highlights that SEC whistleblowers are still eligible for an award when they provide information to the SEC that leads other governmental authorities to successful enforcement actions resulting in monetary proceeds in excess of $1 million.
|$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.
|$3.5 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.
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.
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 (2011-2017), and selected by his peers to be listed in SuperLawyers(2012 and 2015-2017) 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.