Washington, D.C. SEC Whistleblower Attorney – Tier 1 Law Firm
The SEC whistleblower attorneys at Zuckerman Law, a Washington, D.C.-based law firm, represent SEC whistleblowers both domestically and internationally. The firm has a licensed Certified Public Accountant and Certified Fraud Examiner on staff to enhance its ability to investigate complex financial fraud schemes and prepare effective TCR submissions that lead to SEC enforcement actions. Zuckerman Law has helped whistleblowers report a wide variety of fraudulent schemes, including:
- 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 financial measures;
- Improper revenue recognition;
- Violations of auditor independence rules;
- Misleading or incomplete cybersecurity disclosures; and
- Blockchain or initial coin offering fraud.
If you have original information that you would like to report to the SEC Office of the Whistleblower, contact the Director of our SEC Whistleblower Practice at [email protected] 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, our SEC whistleblower lawyers have helped the SEC halt multi-million dollar investment schemes, expose violations at large publicly traded companies, and return funds to defrauded investors.
In contrast to many other SEC whistleblower law firms, our team of SEC whistleblower lawyers includes a Certified Public Accountant and Certified Fraud Examiner with substantial experience auditing public companies and investigating complex fraud schemes.
We understand the many challenges that the SEC faces in investigating our clients’ disclosures and take measures to increase the likelihood that the SEC will be able to effectively pursue the disclosures that our SEC whistleblower lawyers provide on behalf of our clients.
Recently the Association of Certified Fraud Examiners published a profile of Matt Stock’s success working with whistleblowers to fight fraud:
Click below to hear SEC whistleblower attorney Matthew Stock’s tips for SEC whistleblowers:
SEC Whistleblower Awards
Under the SEC Whistleblower Program, whistleblowers may be eligible for monetary awards when they voluntarily provide the SEC with original information about violations of federal securities laws. A whistleblower is eligible to receive between 10% and 30% of the monetary sanctions collected if their tip leads to a successful enforcement action resulting in monetary sanctions exceeding $1,000,000.
The SEC Whistleblower Program also protects the confidentiality of whistleblowers and does not disclose information that might directly or indirectly reveal a whistleblower’s identity. Whistleblowers may submit a tip anonymously through an SEC whistleblower attorney. There is no citizenship requirement to quaify an SEC whistleblower award.
Since Dodd-Frank became effective, the SEC has issued more than $1.9 billion in awards to 397 whistleblowers, which includes awards to our clients totaling millions of dollars. The top SEC whistleblower attorneys can provide critical guidance to whistleblowers throughout this process to protect their identities and increase the likelihood that they not only obtain, but maximize, their awards.
Largest SEC Whistleblower Awards
The table below identifies some of the larger awards that the SEC has provided to whistleblowers:
Whistleblower Award Date Basis for Whistleblower Award
$279 million May 5, 2023 On May 5, 2023, the SEC announced its largest-ever award, nearly $279 million, to a whistleblower whose information and assistance led to the successful enforcement of SEC and related actions.
$114 million October 22, 2020 On October 22, 2020, the SEC announced an 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.
$110 million September 15, 2021 On September 15, 2021, the SEC announced its second-largest whistleblower award of $110 million. According to the press release announcing the award, the award consists of an approximately $40 million award in connection with an SEC case and an approximately $70 million award arising out of related actions by another agency. With the award, the SEC Whistleblower Program has now paid more than $1 billion in awards to whistleblowers.
August 4, 2023 On August 4, 2023, the SEC announced an award of $104 million to seven individuals whose information and assistance led to a successful SEC enforcement action and related actions brought 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.
$36 million September 24, 2021 The Securities and Exchange Commission announced an award of approximately $36 million to a whistleblower "whose information and assistance significantly contributed to the success of an SEC enforcement action as well as actions by another federal agency."
According to the SEC's press release announcing the award, "the whistleblower provided crucial information on an illegal scheme to the SEC's and the other agency's staffs, which included multiple meetings and the identification of key documents and witnesses. Under the SEC's whistleblower program, individuals who provide critical information to other agencies may be eligible for a related action award if they are also eligible for an award in the underlying SEC action."
$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 May 19, 2021 On May 19, 2021, the SEC announced an award to a whistleblower totaling more than $28 million in connection with an SEC enforcement action and a related action by another federal agency. The whistleblower’s information caused both the SEC and the other agency to open investigations that resulted in significant enforcement actions.
$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 May 17, 2021 The SEC awarded almost $27 million to two whistleblowers who provided SEC staff with "new information and assistance during an existing investigation, including meeting with the staff in person on multiple days." According to the SEC's press release, the whistleblowers' "information and cooperation helped the Commission bring the enforcement action, which resulted in the return of millions of dollars to harmed investors."
$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.
$23 million June 2, 2021 The SEC issued two awards of approximately $13 million and $10 million to two whistleblowers whose information and assistance led to successful SEC and related actions. According to the SEC's press release: "The whistleblowers’ information and assistance led to multiple successful enforcement actions related to a complex and fraudulent scheme involving multiple individuals and tens of millions of dollars in ill-gotten gains.”
$22 million May 10, 2021 On May 20, 2021, the SEC issued awards totaling $22 million to two whistleblowers whose information and assistance were of "crucial importance to successful SEC enforcement actions brought against a financial services firm." According to the SEC's press release: "The first whistleblower received an award of $18 million, while the second whistleblower received a $4 million award [because] the first whistleblower was the initial source of the investigation while the second whistleblower submitted information much later after the investigation was already underway."
$22 million September 30, 2021 The SEC issued an award of almost $30 million to two insider whistleblowers whose tips led SEC staff to open an investigation. The first whistleblower, who was the first to alert SEC staff of potential wrongdoing and provided substantial, ongoing assistance, received an award of approximately $22 million. The second whistleblower provided additional valuable information, which significantly contributed to the success of the SEC's enforcement action, and received an award of approximately $7 million.
$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.
SEC Whistleblower Attorney
The SEC whistleblower attorneys at Zuckerman Law will work to quickly provide the highest-quality representation. It is critical that whistleblowers provide timely information to the SEC to maximize the potential of an SEC award. The attorneys will also use lessons drawn from our previous experience representing SEC whistleblowers to offer critical guidance on how to:
(1) maximize the probability of recovering an award; and
(2) maximize the award percentage.
If you have information that you would like to report to the SEC, contact an experienced SEC whistleblower attorney at Zuckerman Law for a free, confidential consultation about your case by calling 202-262-8959.
Tip #1: Quickly Determine Eligibility
Analyzing an individual’s eligibility is complex. The analysis differs depending on the individual’s relation to the company and how the individual obtained the information. For example, auditors may report to the SEC and be eligible for an award if:
- they have a reasonable basis to believe the disclosure is necessary to prevent conduct that is likely to cause “substantial injury” to the financial interest or property of the entity or investors;
- they have a reasonable basis to believe the entity is engaging in “conduct that will impede an investigation of the misconduct”; or
- at least 120 days have passed either since they properly disclosed the information internally, or since they obtained the information under circumstances indicating that the entity’s officers already knew of the information.
Eligibility depends on various factors. If whistleblowers are uncertain about their eligibility, then they should consult with an experienced SEC whistleblower attorney. A skillful analysis may be the difference between a multimillion-dollar whistleblower award and no award at all.
Tip #2: Protect Yourself
Many whistleblowers risk being retaliated against for reporting information to the SEC. Fortunately, the SEC allows whistleblowers to report anonymously if represented by an attorney. If it is imperative that you remain anonymous, you should hire an experienced attorney to skillfully guide you through the process, maximizing the likelihood that your identity is not revealed.
In addition, if an employer retaliates against a whistleblower because of lawful whistleblowing, the Dodd-Frank Act and the Sarbanes-Oxley Act offer substantial protection. In a recent case, a California jury awarded a whistleblower more than $11 million after the whistleblower was terminated for raising concerns about a potential violation of the federal securities laws.
We have substantial experience representing corporate whistleblowers under the whistleblower protection provision of the Sarbanes-Oxley Act.
To learn more about protections for SEC whistleblowers, download our guide Sarbanes-Oxley Whistleblower Protection: Robust Protection for Corporate Whistleblowers.
Tip #3: Know the Rules Before Filing with the SEC
Whistleblowers should be aware of the factors that influence the size of awards before filing with the SEC and apply those factors to get the maximum award. For example, the SEC Whistleblower Office may reduce the amount of an award if the whistleblower:
- unreasonably delayed reporting the violations(s);
- participated in, or was culpable for, the reported securities-law violation; or
- interfered with the company’s internal compliance and reporting systems.
On the other hand, the whistleblower office may increase the amount of an award based on:
- the tip’s significance to the success of any proceeding brought against wrongdoers;
- the assistance that you and your legal representative provide in the SEC action or related action;
- the SEC’s law-enforcement interest in deterring the specific violation; and
- whether, and the extent to which, you participated in your company’s internal compliance and reporting systems.
Accordingly, whistleblowers have an incentive to report internally to their companies’ compliance personnel before going to the SEC.
If a whistleblower reports internally, then the whistleblower generally should also report the same information to the SEC within 120 days. That way, in evaluating a potential award, the SEC will consider the date of the internal report, rather than the date that the whistleblower reported to the SEC. As the SEC puts it, the whistleblower office will “hold your place in line.” This may determine, for example, whether a whistleblower submitted “original information.”
Tip #4: Draft a Tip that Grabs the SEC’s Attention
The SEC Whistleblower Office is relatively small, and thousands of tips are submitted annually. Indeed, the SEC received more than 18,000 whistleblower tips in FY 2023, almost 50% more than the previous record set in FY 2022.
Whistleblowers and their attorneys should tailor their tips to quickly grab the SEC’s attention. While we could write a book on this section alone, here are a few “rules” to keep in mind when drafting submissions:
- Provide the SEC with a clear roadmap for a successful enforcement action. Do not submit a pile of documents and expect the whistleblower office to figure it out. Instead, walk the SEC, step by step, through specific and credible examples of the violation(s).
- Demonstrate how the violation is “material.” As mentioned, the SEC investigates only those violations that are serious enough to warrant the use of its limited resources. While demonstrating materiality, be sure to analyze the legal issues and tie them to the specific violations. This should include a discussion of potential challenges that the SEC may encounter and how the agency should address them.
- If possible, provide the whistleblower office with documentation of the violation. The SEC is much more likely to act on a tip that is supported by strong evidence. The SEC does not, however, want all types of evidence. For example, the SEC does not want information that may violate the company’s attorney-client privilege (e.g., documents, including emails, that involve advice from inside or outside counsel).
Tip #5: Act Fast
The timing of a whistleblower’s tip is a significant factor that the SEC considers in determining whether, and how much, to award the whistleblower. Waiting to file with the SEC runs the risk that someone else may provide the same information to the SEC first, thereby rendering you ineligible for an award.
SEC Whistleblower Attorney’s Guide to SEC Whistleblower Program
The following FAQ about the SEC Whistleblower Program identifies the key facets of the program.
- What is the SEC Whistleblower Program?
- What violations qualify for an SEC whistleblower award?
- How can I submit a tip to the SEC?
- Why should I choose the Zuckerman Law to represent me in my SEC whistleblower claim?
- Can I submit an anonymous tip to the SEC Whistleblower Office?
- When is the best time to report the fraud or misconduct to the SEC?
- Can I submit an SEC Whistleblower claim if the SEC already has an open investigation into the matter?
- Who is an “eligible” SEC whistleblower?
- Can compliance personnel, auditors, officers or directors qualify for an SEC whistleblower award?
- What is “original information”?
- How might my information “lead to” a successful SEC enforcement action?
- Can I submit a claim if I had involvement in the fraud or misconduct?
- Do I have to report a securities law violations to my company before reporting the violation to the SEC?
- Can I submit a tip if I agreed to a confidentiality provision in an employment/severance agreement?
- What factors does the SEC consider when determining the amount of the award?
- What employment protections are available for SEC whistleblowers?
- What type of evidence should I provide to the SEC?
- What happens after I submit a tip to the SEC?
- How long does it take to receive an SEC whistleblower award?
- What are the largest SEC whistleblower awards?
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: