DISCLAIMER

This is a report of the Staff of the U.S. Securities 

and Exchange Commission. The Commission 

has expressed no view regarding the analysis, 

findings, or conclusions contained herein.

DISCLAIMER

This is a report of the Staff of the U.S. Securities 

and Exchange Commission. The Commission 

has expressed no view regarding the analysis, 

findings, or conclusions contained herein.

DISCLAIMER

This is a report of the Staff of the U.S. Securities 

and Exchange Commission. The Commission 

has expressed no view regarding the analysis, 

findings, or conclusions contained herein.

DISCLAIMER

This is a report of the Staff of the U.S. Securities 

and Exchange Commission. The Commission 

has expressed no view regarding the analysis, 

findings, or conclusions contained herein.
CONTENTS

Message from the Chief of the Office of the Whistleblower . . . . . . . . . . . . . . 1

History and Purpose . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

Activities of the Office of the Whistleblower . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Claims for Awards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

Whistleblower Awards Made in Fiscal Year 2017 . . . . . . . . . . . . . . . 10

Overview of Award Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

Profiles of Award Recipients . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

Preserving Individuals’ Rights to Report to the Commission and

Shielding Employees from Retaliation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

Enforcement of Whistleblower Protections . . . . . . . . . . . . . . . . . . . . 19

Protection for Internal Reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

Whistleblower Tips Received ......................................23

Increase in Whistleblower Tips . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

Whistleblower Allegation Type . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

Geographic Origin of Whistleblower Tips . . . . . . . . . . . . . . . . . . . . . 25

Processing of Whistleblower Tips . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

TCR Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

Assistance by OWB . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

Securities and Exchange Commission Investor Protection Fund . . . . . . . . . . 29

Appendix A. Whistleblower Tips by Allegation Type 

Comparison of Fiscal Years 2014–2017 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

Appendix B. Whistleblower Tips Received by 

Geographic Location, United States and its Territories, Fiscal Year 2017 . . . 32

Appendix C. Whistleblower Tips Received by 

Geographic Location, International, Fiscal Year 2017 . . . . . . . . . . . . . . . . . . 33

Report available on the Web at: www.sec.gov/whistleblower

WHISTLEBLOWER PROGRAM | 1

“. . . the value of 

the whistleblower 

program is exhibited 

most directly and 

importantly by the 

hundreds of millions 

of dollars returned to 

investors as a result

of actionable 

information that 

whistleblowers brought 

to the agency.”

M E S S AG E F R O M T H E C H I E F O F T H E 

O F F I C E O F T H E W H I S T L E B LOW E R 

As we enter into the seventh year of the U.S. Securities and Exchange Commission’s 

(SEC, Commission, or agency) whistleblower program, the demonstrable benefits 

of the program continue to materialize. Whistleblowers have provided tremendous 

value to the SEC’s enforcement efforts and significant help to investors. Whistleblower 

information has aided the SEC’s efforts to uncover and stop fraudulent investment 

schemes. But the value of the whistleblower program is exhibited most directly and 

importantly by the hundreds of millions of dollars returned to investors as a result 

of actionable information that whistleblowers brought to the agency. Since the 

program’s inception, the SEC has ordered wrongdoers in enforcement matters involving 

whistleblower information to pay over $975 million in total monetary sanctions, 

including more than $671 million in disgorgement of ill-gotten gains and interest, 

the majority of which has been, or is scheduled to be, returned to harmed investors.

Investor Protection Actions Based on Whistleblower Tips

The Commission brought several enforcement actions in Fiscal Year (FY) 2017 that 

illustrate the critical role whistleblowers play in investor protection. Earlier this fiscal 

year, the SEC awarded a whistleblower who promptly came forward with valuable 

information that enabled the SEC to quickly initiate an enforcement action against 

wrongdoers before they could squander their ill-gotten funds, leading to a near total 

recovery and return of investor funds. Recently, in July 2017, the SEC awarded a 

whistleblower whose critical information helped the agency stop a hard-to-detect 

fraud and return millions of dollars to harmed investors in the process.

In the past year, we have also seen whistleblower information aid SEC staff in detecting 

and stopping active, ongoing investment schemes that directly targeted and victimized 

unsophisticated investors. In January, the Commission awarded a whistleblower who 

provided information that helped end an ongoing fraud that predominately targeted 

a more vulnerable investor community. Also in January of this year, the Commission 

awarded three whistleblowers whose information halted a scheme to which hundreds 

of investors, many of whom were unsophisticated, had fallen victim.

The success of the SEC’s whistleblower program is further illustrated by the number 

and amount of awards over this past year, as well as since the program’s inception. This 

fiscal year, the SEC ordered whistleblower awards totaling nearly $50 million to 12 

individuals. Since the agency issued its first award in 2012 through the end of September 

2017, the program has awarded approximately $160 million in whistleblower awards 

to 46 individuals whose information and cooperation assisted the agency in bringing 

successful Commission enforcement actions and related actions brought by non-SEC 

enforcement authorities.

Awareness of the Whistleblower Program

Awareness of the whistleblower program has grown significantly over the years.

This year, we have continued to experience a consistent increase in the number of 

whistleblower tips received. In FY 2017, we received over 4,400 tips, an increase of 

nearly 50 percent since FY 2012, the first year for which we have full-year data.
2 | U.S. SECURITIES AND EXCHANGE COMMISSION

Whistleblower Protections 

During FY 2017, the Commission brought a number of important actions to address 

instances in which companies unlawfully retaliated against their employees or impeded 

employees’ ability to report freely to the Commission.

In one such action brought in January 2017, the Commission found that HomeStreet, 

Inc., a Seattle-based financial services company, attempted to uncover the identity 

of a presumed whistleblower after being contacted by SEC staff regarding potential 

accounting violations. In its efforts to root out the whistleblower, the company 

suggested that it could deny indemnification for legal costs to the individual whom 

the company believed to be the whistleblower. The company also required former 

employees to sign severance agreements waiving potential whistleblower awards or 

otherwise risk losing their severance payments and other post-employment benefits.

Without admitting or denying the findings, the company agreed to, among other things, 

cease and desist from violating Rule 21F-17 of the Securities Exchange Act of 1934 

(Exchange Act) and pay a $500,000 civil penalty.

The SEC also continued its enforcement of Rule 21F-17 by bringing two actions 

against companies for using restrictive language in separation and severance 

agreements that specifically targeted the Commission’s whistleblower rules 

and incentives. In December 2016, the Commission found that Virginia-based 

technology company NeuStar, Inc. used broad non-disparagement clauses in its 

severance agreements that specifically named the SEC as a regulator to whom 

employees were forbidden from communicating any disparaging information or else 

forfeit all but $100 of their severance. In a subsequent Rule 21F-17 enforcement 

action brought in January 2017, the Commission found that BlackRock, Inc. used 

separation agreements that required departing employees to waive their right to 

receive any incentives for reporting misconduct under the Dodd-Frank Wall Street 

Reform and Consumer Protection Act (Dodd-Frank Act or Dodd-Frank).

The SEC also brought a settled action against Oklahoma-based oil and gas company, 

SandRidge Energy, Inc., for terminating an employee in retaliation for raising concerns 

to company management about how the company calculated its reserves. Along with 

findings that the company had violated the whistleblower anti-retaliation provisions of 

Dodd-Frank, the Commission also found that the company had violated Rule 21F-17 

by entering into separation agreements with hundreds of employees that prohibited 

voluntary, direct communication with the Commission.

Reviewing fact patterns of retaliation against whistleblowers and potential actions 

to impede communications with the Commission will continue to be a focus for the 

Office of the Whistleblower (OWB or Office) in the upcoming fiscal year to ensure that 

whistleblowers can freely report information to the Commission and feel comfortable 

reporting wrongdoing without fear of reprisal.

“Reviewing fact 

patterns of 

retaliation against 

whistleblowers 

and potential 

actions to impede 

communications with 

the Commission will

continue to be a focus 

for the Office of the 

Whistleblower . . .”
WHISTLEBLOWER PROGRAM | 3

Whistleblower Processes

We encourage those who believe they have information concerning a potential securities 

law violation to submit a tip via the online portal on OWB’s webpage (www.sec.

gov/whistleblower) or by submitting a Form TCR, which is also available on OWB’s 

webpage, by mail or fax.

Moreover, to help promote the agency’s whistleblower program and establish a line of 

communication with the public, OWB operates a hotline where whistleblowers, their 

attorneys, or other members of the public with questions about the program may call to 

speak to OWB staff. During FY 2017, we returned nearly 3,200 calls from members of 

the public, exceeding the number of calls returned the prior fiscal year. Since May 2011

when the hotline was established, OWB has returned over 18,600 calls from the public.

If individuals or their counsel have any questions about the program, including 

questions about how to submit a tip to the Commission, we encourage them to call 

OWB’s whistleblower hotline at (202) 551-4790.

Conclusion

We attribute the public’s active interest in the whistleblower program to its three 

key features that Congress created as part of Dodd-Frank: the promise of monetary 

awards to whistleblowers whose information leads to successful enforcement actions, 

provisions to safeguard whistleblower confidentiality, and enhanced anti-retaliation 

protections. We believe that these features will continue to incentivize company insiders, 

market participants, and others with knowledge of potential securities law violations 

to step forward and report their information to the agency. And we expect that the

Commission will continue to receive high-quality tips that can be leveraged to detect 

and halt fraud earlier and more effectively.

We are proud that the whistleblower program continues to positively impact the SEC’s 

enforcement of the federal securities laws. We are confident that it will continue to 

bolster the agency’s mission of protection of investors and the markets in the years ahead.

JANE NORBERG

Chief, Office of the Whistleblower

November 15, 2017

“. . . we expect that

the Commission will 

continue to receive 

high-quality tips that 

can be leveraged to 

detect and halt fraud 

earlier and more

effectively.”
4 | U.S. SECURITIES AND EXCHANGE COMMISSION

HISTORY AND PURPOSE

The Dodd-Frank Act1 amended the Exchange Act2 by, among other things, adopting 

Section 21F,3 entitled “Securities Whistleblower Incentives and Protection.” Section 

21F directs the Commission to make monetary awards to eligible individuals 

who voluntarily provide original information that leads to successful Commission 

enforcement actions resulting in monetary sanctions over $1 million and successful 

related actions.

4

Awards must be made in an amount equal to 10 to 30 percent of the monetary 

sanctions collected.

5

 To ensure that whistleblower payments would not diminish 

the amount of recovery for victims of securities law violations, Congress established 

a separate fund, called the Investor Protection Fund (Fund), from which eligible 

whistleblowers are paid.

The Commission established OWB, an office within the SEC’s Division of Enforcement 

(Enforcement), to administer and effectuate the whistleblower program. It is OWB’s 

mission to administer a vigorous whistleblower program that will help the Commission 

identify and halt securities frauds early and quickly to minimize investor losses.

In addition to establishing an awards program to encourage the submission of highquality information, Dodd-Frank and the Commission’s implementing regulations 

(Whistleblower Rules)6 prohibit retaliation by employers against employees who report 

possible wrongdoing based on a reasonable belief that a possible securities violation has 

occurred, is in progress, or is about to occur.

7

In adopting the Whistleblower Rules, the Commission recognized that whistleblower 

reporting through internal compliance procedures can enhance the Commission’s 

enforcement efforts in appropriate circumstances.

8

 Consequently, the Commission 

adopted strong incentives and protections for employees who choose to work within 

their company’s own compliance structure because they believe that the employer’s 

internal compliance function is an effective mechanism to address any potential 

wrongdoing.

9

1 Pub. L. No. 111-203, § 922(a), 124 Stat. 1841 (2010).

2 15 U.S.C. § 78a, et seq.

3 Id. § 78u-6.

4 “Related actions” is defined at 15 U.S.C. § 78u-6(a)(5) and 17 C.F.R. § 240.21F-3(b).

5 15 U.S.C. § 78u-6(b)(1).

6 17 C.F.R. § 240.21F-1 through 21F-17.

7 15 U.S.C. § 78u-6(h)(1); 17 C.F.R. § 240.21F-2(b).

8 Securities Whistleblower Incentives and Protections, 76 Fed. Reg. 34,300, 34,359 n.450 (June 13, 2011).

9 See 17 C.F.R. §§ 240.21F-4(b)(7), 240.21F-6(a)(4), (b)(3).
WHISTLEBLOWER PROGRAM | 5

Dodd-Frank’s Section 924(d) requires OWB to report annually to Congress on 

OWB’s activities, whistleblower complaints received, and the response of the 

Commission to such complaints.

10 In addition, Section 21F(g)(5) of the Exchange Act 

requires the Commission to submit an annual report to Congress that addresses the 

following subjects:

• The whistleblower award program, including a description of the number of 

awards granted and the types of cases in which awards were granted during the 

preceding fiscal year;

• The balance of the Fund at the beginning of the preceding fiscal year;

• The amounts deposited into or credited to the Fund during the preceding 

fiscal year;

• The amount of earnings on investments made under Section 21F(g)(4) during the 

preceding fiscal year;

• The amount paid from the Fund during the preceding fiscal year to whistleblowers 

pursuant to Section 21F(b);

• The balance of the Fund at the end of the preceding fiscal year; and

• A complete set of audited financial statements, including a balance sheet, 

income statement, and cash flow analysis.

11

OWB, in consultation with other offices within the Commission, has prepared this 

report to satisfy the reporting requirements of Section 924(d) of the Dodd-Frank Act 

and Section 21F(g)(5) of the Exchange Act. The sections in this report addressing 

the activities of OWB, the whistleblower tips received during FY 2017, and the 

processing of whistleblower tips primarily address the requirements of Dodd-Frank’s 

Section 924(d). The sections addressing the Fund and whistleblower incentive awards 

made during FY 2017 primarily address the requirements of Section 21F(g)(5) of the 

Exchange Act.

10 15 U.S.C. § 78u-7(d).

11 15 U.S.C. § 78u-6(g)(5).
6 | U.S. SECURITIES AND EXCHANGE COMMISSION

AC T I V I T I E S O F T H E O F F I C E O F T H E 

WHISTLEBLOWER

Section 924(d) of the Dodd-Frank Act directed the Commission to establish a separate 

office within the Commission to administer and enforce the provisions of Section 21F 

of the Exchange Act. Jane Norberg heads the Office as Chief of OWB. In May 2017, 

Emily Pasquinelli was promoted to Deputy Chief to fill the role vacated by Ms. Norberg 

when she was promoted to Chief. Additionally, OWB is staffed by eleven attorneys, 

four paralegals, and an administrative assistant. Below is an overview of OWB’s 

primary responsibilities and activities over the past fiscal year.

Assessment of Award Applications 

The whistleblower program was designed, in part, to provide a monetary incentive to 

corporate insiders and others with relevant information concerning potential securities 

violations to report their information to the Commission. As such, much of OWB’s 

work relates to the assessment of claims for whistleblower awards.

OWB posts a Notice of Covered Action (NoCA) on its webpage (www.sec.gov/

whistleblower/claim-award) for every Commission enforcement action that results in 

monetary sanctions of over $1 million. Anyone who believes that (s)he is entitled to a 

whistleblower award may submit an application in response to a posted NoCA. Before 

submitting an application, however, a whistleblower should ensure that there is a nexus 

between a whistleblower tip that (s)he provided to the Commission and what was 

ultimately charged in the enforcement matter.

OWB staff tracks investigations where a whistleblower has provided information or 

assistance to Enforcement staff. This case-tracking initiative provides early information 

to OWB about which matters may ultimately result in an award payout and allows 

OWB staff to provide subject matter expertise to Enforcement staff on whistleblower 

investigations, as needed. Although it is ultimately a whistleblower’s responsibility to 

make a timely application for an award, OWB may contact whistleblowers who have 

been actively working with Enforcement staff—or who have previously contacted the 

office about the posting of a particular covered action—to confirm they are aware of the 

posting and applicable deadline for submitting claims for award.

After receiving an application for an award, OWB attorneys assess the application 

and the eligibility of the claimant and confer with relevant Enforcement or other 

Commission staff to understand the contribution of the claimant, if any, to the covered 

action. OWB then makes recommendations to the Claims Review Staff, currently 

comprised of five senior officers in Enforcement, as to award eligibility. Pages 10-15 of 

this report provide a fuller explanation of how applications for awards are processed at 

the Commission, as well as what awards were made during FY 2017.

Reviewing Restrictive Agreements 

During FY 2017, OWB focused on employers’ usage of confidentiality, severance, 

and other kinds of agreements, or engagement in other practices, to interfere with 

individuals’ ability to report potential wrongdoing to the SEC. Exchange Act Rule 

21F-17(a) provides that “[n]o person may take any action to impede an individual 

“. . . OWB focused 

on employers’ usage 

of confidentiality, 

severance, and other 

kinds of agreements, 

or engagement in 

other practices, to

interfere with 

individuals’ ability 

to report potential 

wrongdoing to 

the SEC.”
WHISTLEBLOWER PROGRAM | 7

from communicating directly with the Commission staff about a possible securities 

law violation, including enforcing, or threatening to enforce, a confidentiality 

agreement ... with respect to such communications.”12 In FY 2017, the Commission 

instituted administrative proceedings against four companies for violating Rule 

21F-17(a). OWB continues to work closely with investigative staff to identify and 

investigate practices in the use of confidentiality and other kinds of agreements, or 

other actions, that may violate Rule 21F-17(a). For more information about these 

activities, please see pages 19-21 of this report.

Advancing Anti-Retaliation Protections

OWB identifies and monitors whistleblower complaints alleging retaliation by employers 

or former employers in response to an employee’s reporting of possible securities law 

violations internally or to the Commission. The Commission may bring an enforcement 

action against companies or individuals who violate the anti-retaliation provisions of 

the Dodd-Frank Act. In FY 2017, the Commission brought a retaliation case against a 

company for retaliating against an employee who reported concerns of possible securities 

laws violations internally to his company, but did not also separately report to the 

Commission. Bringing retaliation cases illustrates the high priority placed on ensuring an 

environment where whistleblowers can report internally or to the Commission without 

fear of reprisal. OWB continues to work with Enforcement staff to identify cases where 

companies and individuals take reprisals against employees for whistleblowing efforts 

that may be appropriate for enforcement action.

OWB also monitors federal court cases involving the anti-retaliation provisions of 

the Dodd-Frank Act and the Sarbanes-Oxley Act of 2002.

13 OWB works with the 

SEC’s Office of General Counsel, which has filed amicus curiae briefs on behalf of 

the Commission and appeared in federal courts around the country advocating the 

Commission’s position that anti-retaliation protections under Dodd-Frank apply to 

employees who report potential violations of the securities laws internally or to other 

federal law enforcement agencies without also having informed the Commission of 

the same.

14 On June 26, 2017, the United States Supreme Court granted certiorari 

in Digital Realty Trust, Inc. v. Somers to address a lower court split on the scope of 

the Dodd-Frank Act anti-retaliation protections.

15 On October 17, 2017, the United 

States Solicitor General, acting on behalf of the Department of Justice and joined by 

the Commission, filed an amicus curiae brief in the Supreme Court in support of the 

whistleblower-respondent. The United States’ amicus curiae brief in Digital Realty

continues the Commission’s advocacy efforts and urges the Supreme Court to recognize 

that Dodd-Frank’s statutory language, its legislative history, and the Commission’s 

rules require that individuals who internally report potential securities violations at a 

publicly-traded company are entitled to employment retaliation protection, regardless of 

whether they have separately reported that information to the Commission. For more 

information about these activities, please see pages 21-22 of this report.

12 17 C.F.R. § 240.21F-17(a).

13 18 U.S.C. § 1514A.

14 The SEC’s interpretive guidance may be found on OWB’s webpage, www.sec.gov/whistleblower/retaliation, and 

also has been published in the Federal Register at 80 Fed. Reg. 47,829 (Aug. 10, 2015).

15 850 F.3d 1045 (9th Cir. 2017), cert. granted, No. 16-1276 (U.S. June 26, 2017).
8 | U.S. SECURITIES AND EXCHANGE COMMISSION

Intake of Whistleblower Tips 

The Commission has an internal database called the Tips, Complaints, and Referrals 

Intake and Resolution System (TCR System) that serves as a central repository for all 

tips and complaints received by the Commission, as well as referrals from self-regulatory

organizations and other government agencies. Exchange Act Rule 21F-9 provides 

whistleblowers the option to submit tips either electronically through an online portal 

that feeds directly into the TCR System or by mailing or faxing a hard-copy Form TCR 

directed to OWB. This flexibility supports whistleblowers who may not have ready 

access to a computer or who, for other reasons, may prefer to submit their information 

in hard copy. In cases where whistleblowers elect to submit a hard-copy Form TCR, 

OWB and other SEC staff manually enter the tips into the TCR System so they can 

be appropriately reviewed, assigned, and tracked in the same manner as tips received 

through the online portal. For more information on the number and types of tips 

received, please refer to pages 23-26 of this report.

Communications with Whistleblowers

OWB serves as the primary liaison between the Commission and individuals who 

have submitted information or are considering whether to submit information to 

the agency concerning a possible securities violation. OWB created a whistleblower 

hotline, in operation since May 2011, to respond to questions from the public about 

the whistleblower program. Individuals may leave messages on the hotline by calling 

(202) 551-4790. All calls to the hotline are returned by OWB attorneys within 

24 business hours (3 business days).

During FY 2017, the Office returned nearly 3,200 phone calls from members of the 

public. Many of the calls OWB receives relate to how the caller should submit a tip 

to be eligible for an award, how the Commission will maintain the confidentiality 

of a whistleblower’s identity, requests for information on the investigative process 

or tracking an individual’s complaint status, and whether the SEC is the appropriate 

agency to handle the caller’s tip. OWB recently updated the hotline voicemail to 

provide a menu of options with answers to frequently asked questions.

In addition to communicating with whistleblowers through the hotline, the Office sends 

letters to whistleblowers who have submitted tips, additional information, claims for 

awards, and other correspondence to OWB.

“During FY 2017, 

the Office 

returned nearly 

3,200 phone calls 

from members 

of the public.”
WHISTLEBLOWER PROGRAM | 9

Public Outreach and Education 

One of the Office’s primary goals is to promote public awareness of the Commission’s 

whistleblower program. As part of that outreach effort, the Office aims to promote 

the whistleblower program, and educate the public about the whistleblower program, 

through OWB’s webpage (www.sec.gov/whistleblower). The webpage contains 

information about the program, copies of the forms required to submit a tip or claim 

an award, a listing of enforcement actions for which a claim for award may be made, 

links to helpful resources, and answers to frequently asked questions. In FY 2017, the 

Office updated its webpage to provide the public with additional information about 

the whistleblower program, including adding a new section dedicated to retaliationrelated issues.

OWB also actively participates in numerous webinars, media interviews, presentations, 

press releases, and other public communications. In FY 2017, OWB participated in 

many public engagements aimed at promoting and educating the public about the 

Commission’s whistleblower program. The Office’s target audience generally includes 

potential whistleblowers, whistleblower counsel, and corporate compliance counsel and 

professionals. OWB’s Chief has also participated in legal panels and other forums with 

other federal agencies with similar whistleblower programs.
10 | U.S. SECURITIES AND EXCHANGE COMMISSION

CLAIMS FOR AWARDS

Whistleblower Awards Made in Fiscal Year 2017

In FY 2017, the Commission ordered whistleblower awards of nearly $50 million to 

12 individuals, each of whom provided new information, of which the agency was 

previously unaware, that either led to the opening of an investigation or significantly 

contributed to a successful enforcement action.

Below are the top ten highest awards made under the SEC’s whistleblower program 

through FY 2017.

$5.5 million

$5–6 million

$4 million

$3.5 million

$30 million

$22 million

$20 million

$17 million

$14 million

$7 million

TOP 10 SEC WHISTLEBLOWER AWARDS

From program inception to end of Fiscal Year 2017, the SEC awarded 

approximately $160 million to 46 whistleblowers.

September 2014

August 2016

November 2016

June 2016

September 2013

January 2017

January 2017

May 2016

September 2016

May 2016

As reflected in the graphic, three of the ten largest whistleblower awards were made 

by the Commission during FY 2017. The more than $30 million award issued by the 

Commission in September 2014 remains the highest award made to date under 

the program.

16

Below is an overview of the whistleblower awards made by the SEC during the past 

fiscal year.

Third-Highest Award of Over $20 Million 

On November 14, 2016, the Commission announced an award of more than 

$20 million to a whistleblower who promptly came forward with valuable information 

that enabled the SEC to quickly initiate an enforcement action against wrongdoers before 

they could squander the money, leading to a near total recovery of investor funds.

17 This 

was the third-highest award made since the program issued its first award in 2012.

16 See Order Determining Award Claim, Exchange Act Rel. No. 73174, File No. 2014-10 (Sept. 22, 2014); 

SEC Press Rel. No. 2014-206, “SEC Announces Largest-Ever Whistleblower Award.” 

17 See Order Determining Award Claim, Exchange Act Rel. No. 79294, File No. 2017-1 (Nov. 14, 2016); 

SEC Press Rel. No. 2016-237, “SEC Issues $20 Million Whistleblower Award.”
WHISTLEBLOWER PROGRAM | 11

$7 Million Awarded to Three Whistleblowers

On January 23, 2017, the Commission announced an award of more than $7 million 

to three whistleblowers who helped the SEC stop an investment scheme that defrauded 

hundreds of investors, many of whom were unsophisticated.

18 One whistleblower 

provided information that was the primary impetus for the beginning of the 

Commission’s investigation. This individual received an award of more than $4 million.

The other two whistleblowers split more than $3 million for voluntarily providing new 

information during the SEC’s investigation that significantly contributed to the success 

of the Commission’s action.

Company Insider Receives $5.5 Million Award

On January 6, 2017, the Commission announced an award of more than $5.5 million 

to a company insider who provided information that led to a successful Commission 

enforcement action.

19 Not only did the information help open the investigation, but the 

whistleblower also continued to provide information and assistance throughout the 

course of the investigation, which ultimately helped end an ongoing fraud that chiefly 

targeted a vulnerable investor community.

$4 Million Award to Whistleblower for Providing 

Industry-Specific Expertise

On April 25, 2017, the Commission announced an award of almost $4 million to 

a whistleblower whose information was the primary cause for an investigation’s 

opening.

20 The whistleblower provided industry-specific knowledge and expertise that 

allowed the Commission to effectively bring the underlying action with fewer resources.

$3.5 Million Award

On December 5, 2016, the Commission announced an award of nearly $3.5 million 

to a whistleblower who came forward with information that led to a successful SEC 

enforcement action.

21

Information Launched Investigation and Earned Whistleblower a 

$2.5 Million Award

On July 25, 2017, the Commission announced an award of nearly $2.5 million to an 

employee of a domestic government agency whose whistleblower tip helped launch 

an SEC investigation and whose continued assistance enabled the SEC to address a 

company’s misconduct.

22 This individual provided timely ongoing assistance along 

with critical documents that accelerated the pace of the Commission’s enforcement 

investigation.

18 See Order Determining Award Claim, Exchange Act Rel. No. 79853, File No. 2017-6 (Jan. 23, 2017); 

SEC Press Rel. No. 2017-27, “SEC Announces $7 Million Whistleblower Award.”

19 See Order Determining Award Claim, Exchange Act Rel. No. 79747, File No. 2017-5 (Jan. 6, 2017); 

SEC Press Rel. No. 2017-1, “SEC Awards $5.5 Million to Whistleblower,”

20 See Order Determining Award Claim, Exchange Act Rel. No. 80521, File No. 2017-8 (Apr. 25, 2017); SEC 

Press Rel. No. 2017-84, “SEC Awards Nearly $4 Million to Whistleblower.”

21 See Order Determining Award Claim, Exchange Act Rel. No. 79464, File No. 2017-2 (Dec. 5, 2016); 

SEC Press Rel. No. 2016-255, “SEC Awards $3.5 Million to Whistleblower.”

22 See Order Determining Award Claim, Exchange Act Rel. No. 81200, File No. 2017-12 (July 25, 2017); 

SEC Press Rel. No. 2017-130, “SEC Announces $2.5 Million Whistleblower Award.”
12 | U.S. SECURITIES AND EXCHANGE COMMISSION

Company Insider Awarded More than $1.7 Million for Help with 

Difficult to Detect Fraud

On July 27, 2017, the Commission announced a whistleblower award of more than 

$1.7 million to a company insider who provided the agency with critical information to 

help stop a fraud that would have otherwise been difficult to detect.

23 Millions of dollars 

were returned to harmed investors as a result of the SEC’s ensuing investigation and 

enforcement action.

Award of More Than $900,000 for Assistance with Multiple Actions

On December 9, 2016, the Commission announced an award of more than $900,000 

to a whistleblower whose tip enabled the SEC to bring multiple enforcement actions 

against wrongdoers.

24

Award of More Than $500,000

On May 2, 2017, the Commission ordered an award of more than $500,000 to a 

company insider whose information prompted the Commission’s investigation of 

a well-hidden and hard-to-detect securities violation.

25 This award highlights how 

company insiders are in a unique position to provide specific information that allows 

the Commission to better protect investors and the marketplace.

20 Percent Award

On February 28, 2017, the Commission announced a whistleblower award of 

20 percent of amounts collected or to be collected to a whistleblower who voluntarily 

provided original information to the agency that led to a successful enforcement 

action.

26

“Millions of dollars 

were returned to 

harmed investors 

as a result of 

the SEC’s ensuing 

investigation and 

enforcement 

action.

”

23 See Order Determining Award Claim, Exchange Act Rel. No. 81227, File No. 2017-13 (July 27, 2017); 

SEC Press Rel. No. 2017-134, “SEC Announces Whistleblower Award of More Than $1.7 Million.”

24 See Order Determining Award Claim, Exchange Act Rel. No. 79517, File No. 2017-3 (Dec. 9, 2016); 

SEC Press Rel. No. 2016-260, “SEC Awards Nearly $1 Million to Whistleblower.”

25 See Order Determining Award Claim, Exchange Act Rel. No. 80571, File No. 2017-9 (May 2, 2017); SEC 

Press Rel. No. 2017-90, “Whistleblower Award of More Than Half-Million Dollars for Company Insider.”

26 See Order Determining Award Claim, Exchange Act Rel. No. 80115, File No. 2017-7 (Feb. 28, 2017).
WHISTLEBLOWER PROGRAM | 13

Overview of Award Process 

For a whistleblower to receive an award, there are a number of preconditions that must 

be met. The diagram below provides a snapshot of the overall process, from the filing 

of the whistleblower tip to payment of the whistleblower award. As reflected, the time 

between the submission of a whistleblower tip and when an individual may receive an 

award payment can be several years, particularly where the underlying investigation is 

especially complex, where there are multiple, competing award claims, or where there 

are claims for related actions.

The discussion below focuses on the award claims process, from the posting of the 

NoCA to the issuance of a Final Order by the Commission.

NoCA Posted 

The Office posts on its webpage a NoCA for each Commission enforcement action 

where a final judgment or order, by itself or together with other judgments or orders in 

the same action issued after July 21, 2010, results in monetary sanctions exceeding 

$1 million.

27 During FY 2017, OWB posted 193 NoCAs.

OWB announces on Twitter each time a new group of NoCAs is posted to its 

webpage, and sends email alerts to GovDelivery when the NoCA listing is updated.

28

Whistleblowers and other members of the public may sign up to receive an update via 

email every time the list of NoCAs on OWB’s webpage is updated. OWB posts new 

NoCAs on its webpage on the last business day of each month.

27 OWB posts a NoCA for every enforcement action that results in monetary sanctions exceeding $1 million.

By posting a NoCA for a particular case, the Commission is not making a determination either that a 

whistleblower tip, complaint or referral led to the Commission opening an investigation or filing an action 

with respect to the case or that an award to a whistleblower will be paid in connection with the case.

28 GovDelivery is a vendor that provides communications for public-sector clients.
14 | U.S. SECURITIES AND EXCHANGE COMMISSION

Award Claim Submitted

Once a NoCA is posted, individuals have 90 calendar days to apply for an award 

by submitting a completed award application on Form WB-APP to OWB.

29 It is the 

responsibility of the claimant to make a timely application for award. The Commission 

has denied late-filed award claims. The Court of Appeals for the Second Circuit recently 

upheld the Commission’s denial of two claimants whose award applications were 

submitted approximately two years after the required deadline.

30 As such, we encourage 

whistleblowers and their counsel to regularly review the monthly NoCA postings or to 

sign up to receive emails to alert them as to when new NoCAs are posted.

Award Claim Reviewed

OWB attorneys evaluate each application for a whistleblower award. OWB works 

closely with investigative staff responsible for the relevant action, as well as other 

Commission staff who may have interacted with the claimant, to understand the 

contribution or involvement the applicant may have had in the matter.

Utilizing the information and materials provided by the claimant in support of 

the application, as well as other relevant materials, OWB prepares a written 

recommendation to the Claims Review Staff as to whether the applicant meets the 

criteria for receiving an award, and if so, the percentage of the award.

Preliminary Determination Issued

The Claims Review Staff, designated by the co-Directors of Enforcement, considers 

OWB’s recommendation on the award application in accordance with the criteria 

set forth in the Dodd-Frank Act and the Whistleblower Rules. The Claims Review 

Staff currently is composed of five senior officers in Enforcement, including one of 

the co-Directors of Enforcement. The Claims Review Staff then issues a Preliminary 

Determination setting forth its assessment of whether the claim should be allowed or 

denied and, if allowed, setting forth the proposed award percentage amount.

31

The Whistleblower Rules outline a number of positive and negative factors that the 

Commission and Claims Review Staff may consider in assessing an individual’s award 

percentage. Award percentages are based on the particular facts and circumstances of 

each case, and are not based on any hard-set mathematical formula.

Factors that may increase an award percentage include the significance of the 

information provided by the whistleblower, the level of assistance provided by the 

whistleblower, the law enforcement interests at stake, and whether the whistleblower 

reported the violation internally through his or her firm’s internal reporting channels 

or mechanisms.

Factors that may decrease an award percentage include whether the whistleblower was 

culpable or involved in the underlying misconduct, interfered with internal compliance 

systems, or unreasonably delayed in reporting the violation to the Commission.

“Once a NoCA is 

posted, individuals 

have 90 calendar 

days to apply for an 

award by submitting 

a completed award 

application on Form 

WB-APP to OWB.

”

29 17 C.F.R. §§ 240. 21F-10(a), (b).

30 Cerny v. SEC, No. 16-934, 2017 WL 3911581 (2d Cir. Sept. 7, 2017) (affirming Order Determining 

Whistleblower Award Claim, Exchange Act Rel. No. 77368 (Mar. 14, 2016)).

31 17 C.F.R. § 240.21F-10(d).
WHISTLEBLOWER PROGRAM | 15

Record and Reconsideration Requested

An applicant may submit a written request within 30 calendar days of the date of the 

Preliminary Determination asking for a copy of the record that formed the basis of the 

Claims Review Staff’s decision as to the applicant’s claim for award. As a precondition 

to receiving a copy of the record, OWB requires claimants and their counsel, if the 

claimant is represented, to execute a confidentiality agreement limiting the use of such 

materials to the claims review process.

32 A claimant also has 30 calendar days to request 

a meeting with OWB, which OWB may grant at its discretion.

Claimants may seek reconsideration of the Preliminary Determination by submitting 

a written response to OWB within 60 calendar days of the later of (i) the date of the 

Preliminary Determination, or (ii) if the record was requested, the date when OWB 

made the record available for a claimant’s review.

33 If a claim is denied and the applicant 

does not object within the time period prescribed under the Whistleblower Rules, then 

the Preliminary Determination of the Claims Review Staff becomes the Final Order of 

the Commission.

Final Order Issued

After considering any requests for reconsideration, the Claims Review Staff issues a 

Proposed Final Determination, and the matter is submitted to the Commission for 

its decision.

34

All Preliminary Determinations of the Claims Review Staff that involve granting 

an award are submitted to the Commission for consideration as Proposed Final 

Determinations irrespective of whether the applicant objected to the Preliminary 

Determination.

35

Within 30 days of receiving the Proposed Final Determination, any Commissioner may 

request that the Proposed Final Determination be reviewed by the Commission. If no 

Commissioner requests such a review within the 30-day period, then the Proposed Final 

Determination becomes the Final Order of the Commission. Claimants who are issued 

a denial have a right to appeal the Commission’s Final Order within 30 days of issuance 

to the United States Court of Appeals for the District of Columbia Circuit, or to the 

circuit where the claimant resides or has his or her principal place of business.

36

Final Orders of the Commission are publicly available on the Commission’s website 

and OWB’s webpage. The public Final Orders are redacted to protect award applicants’ 

confidentiality.

32 Id. § 240.21F-12(b). Rule 21F-12(b) states, “The Office of the Whistleblower may also require you to 

sign a confidentiality agreement, as set forth in § 240.21F-(8)(b)(4) of this chapter, before providing 

[Preliminary Determination] materials.”

33 17 C.F.R. § 240.21F-10(e).

34 Id. §§ 240.21F-10(g), (h).

35 Id. §§ 240.21F-10(f), (h).

36 Id. § 240.21F-10(h). A whistleblower’s rights of appeal from a Commission Final Order are set forth in 

Section 21F(f) of the Exchange Act, 15 U.S.C. § 78u-6(f), and Exchange Act Rule 21F-13(a), 17 C.F.R.

§ 240.21F-13(a).
16 | U.S. SECURITIES AND EXCHANGE COMMISSION

P R O F I L E S O F AWA R D R E C I P I E N T S 

Protecting whistleblower confidentiality is an integral component of the whistleblower 

program. The Dodd-Frank Act prohibits the Commission and its staff from disclosing 

any information that reasonably could be expected to reveal the identity of a 

whistleblower, subject to certain exceptions. Consequently, information that may tend 

to reveal a whistleblower’s identity is redacted from Commission orders granting or 

denying awards before they are issued publicly. This may include redacting the name of 

the enforcement action upon which the award is based.

Consistent with our statutory obligation to maintain whistleblower confidentiality but 

in an effort to provide more transparency, this section provides information about the 

profiles of past award recipients—from the whistleblower program’s inception to the 

end of FY 2017—while still protecting the identity of any particular individual.

Since program inception, the Commission has issued awards of approximately $160 

million to 46 individuals in connection with 37 covered actions, as well as in connection 

with several related actions. Many of the tips or complaints that were submitted by 

these successful whistleblowers share similar characteristics. The information provided 

by each award recipient was specific. For example, the whistleblower identified 

particular individuals involved in the misconduct, or provided specific documents that 

substantiated their allegations or explained where such documents could be located. In 

some instances, the whistleblower identified specific financial transactions that evidenced 

fraud, or provided detailed assessment of the 

wrongdoing. The misconduct reported by 

award recipients was often relatively 

current or ongoing at the time it was 

reported to the Commission. Additionally, 

the vast majority of award recipients 

provided Commission staff with additional 

assistance and/or information (e.g., answered 

staff questions or provided testimony) after 

they submitted their initial tips.

An individual may be eligible to receive an 

award where her or his information leads to a successful enforcement action—meaning 

generally that the original information either caused an examination or investigation to 

open, or the original information significantly contributed to a successful enforcement 

action where the matter was already under examination or investigation. The majority 

of the whistleblowers who have received 

awards under the program provided original 

information that caused Enforcement staff 

to open an investigation, and a significant 

percentage received awards because their 

original information assisted with an 

already-existing investigation. In assessing 

whether information assisted with an 

already-existing enforcement action, the 

96%

4%

Additional Assistance After Initial Tip

Did not 

provide

additional

assistance

Provided 

additional

assistance

34%

66%

Led to Successful Enforcement Action

By opening 

investigation 

or exam

By assisting with 

already-existing 

investigation

“Protecting 

whistleblower 

confidentiality is 

an integral 

component of the 

whistleblower 

program.”
WHISTLEBLOWER PROGRAM | 17

Commission will consider factors such as whether the information allowed the agency 

to bring the action in significantly less time or with fewer resources, and whether 

it supported additional successful charges, or successful claims against additional 

individuals or entities.

37 When the Commission has found claimants to be ineligible for 

awards on non-procedural grounds, it is often because the claimants’ information did not 

open an investigation or exam, open a new line of inquiry in an existing investigation, or 

significantly contribute to an existing investigation.

There is no requirement under the Whistleblower Rules that an individual be an 

employee or company insider to be eligible for an award. However, about 62 percent of 

the award recipients to date were current or former insiders of the entity about which 

they reported information of wrongdoing to the SEC. Of the award recipients who were 

current or former employees of a subject entity, almost 83 percent raised their concerns 

internally to their supervisors, compliance personnel, or through internal reporting 

mechanisms, or understood that their supervisor or relevant compliance personnel knew 

of the violations, before reporting their information of wrongdoing to the Commission.

25%

15%

19%

4% 7%

30%

Whistleblower Award Recipients

Current employees

Former employees

Other types of insiders 

(including consultants or close 

affiliates of subject company)

Industry professionals

Harmed or 

prospective investors

Other types of outsiders

83%

17%

Internal Reporting by Current and Former Employees or 

Supervisor/Compliance Already Aware of Violations

Reported internally 

or supervisor/ 

compliance aware

Did not report

As reflected in the left chart above, whistleblowers may obtain information of possible 

wrongdoing by a subject company or individual that is not their employer. Although 

the majority were employees or former employees of the company involved in the 

wrongdoing, the remaining award recipients obtained their information because they 

were either investors who had been victims of the fraud, professionals working in the 

same or a related industry, or other types of outsiders, such as individuals who had a 

personal relationship with the wrongdoer.

Whistleblowers seeking an award are not required to be represented by counsel unless 

they choose to file their tips with the Commission anonymously. About 46 percent of 

the award recipients did not have counsel when they initially submitted their tips to 

the agency. The other 54 percent were represented by counsel, 19 percent of which 

filed anonymously. Some of the individuals who were not represented by counsel at the 

time they submitted their tips subsequently retained counsel during the course of the 

investigation or during the whistleblower award application process (although retaining 

counsel is not required to file for a whistleblower award).

37 Securities Whistleblower Incentives and Protections, 76 Fed. Reg. 34,300, 34,325 (June 13, 2011).
18 | U.S. SECURITIES AND EXCHANGE COMMISSION

Whistleblowers help the Commission bring 

cases against a variety of defendants, many 

of which are involved in the financial 

services industry. Twenty-eight percent of 

the cases in which a whistleblower received 

an award concerned corporate defendants 

registered with the Commission, including 

broker-dealers, investment advisers, or 

other registered market participants.

Whistleblowers also have contributed 

to enforcement actions against individuals and unregistered entities responsible for 

securities law violations. Individuals comprised 47 percent of the defendants, and 

unregistered entities and companies 25 percent of the defendants, in cases resulting in 

whistleblower awards.

25%

47%

28%

Defendants for Covered Actions

Registered entities

Private entities or 

companies (unregistered)

Individuals (registered and 

unregistered)

Additionally, whistleblowers have assisted 

the Commission in bringing enforcement 

cases involving an array of securities 

violations . A number of the award 

recipients reported information to the 

Commission concerning offering frauds, 

such as Ponzi or Ponzi-like schemes . Other 

award recipients provided tips to the 

Commission relating to false or misleading 

statements in a company’s offering 

memoranda or marketing materials, false 

pricing information, accounting, and 

internal controls violations, among other 

types of misconduct . The chart above reflects the diversity of securities violations in 

which award recipients have been involved in reporting .

8%

9%

22%

11%

28%

22%

Primary Securities Violations for Covered Actions

Misrepresentation/

omission violations

Corporate/issuer 

disclosure violations 

(including FCPA, 

accounting, and offering 

document violations)

Offering fraud 

(including Ponzi and 

pyramid schemes)

Trading violations 

(including insider trading)

Sales and advisory 

practices violations

Other (including 

operational, registration, 

and fees/markups/

commissions violations)

Under the Whistleblower Rules, individuals are permitted to jointly submit a tip to the 

Commission . Six of the matters for which whistleblower awards were ordered involved 

two or more whistleblowers jointly submitting information and materials to the 

Commission . 

Individuals who provide information that leads to successful SEC actions resulting in 

monetary sanctions over $1 million also may be eligible to receive an award if the same 

information led to a related action, such as a parallel criminal prosecution . Six of the 

award recipients have received payments based, in part, on collections made in related 

criminal or other qualifying related actions . 

Past whistleblower award recipients hail from several different parts of the United 

States, and nine recipients were foreign nationals or residents of foreign countries at the 

time they submitted their tips to the Commission .
WHISTLEBLOWER PROGRAM | 19

P R E S E R V I N G I N D I V I D U A L S ’ R I G H T S T O 

R E P O R T T O T H E C O M M I S S I O N A N D S H I E L D I N G 

EMPLOYEES FROM RETALIATION

Section 21F(h)(1) of the Dodd-Frank Act expanded protections for whistleblowers and 

broadened prohibitions against retaliation.

38 Following the passage of Dodd-Frank, the 

SEC implemented rules that enabled the SEC to take legal action against employers who 

have retaliated against whistleblowers. This generally means that employers may not 

discharge, demote, suspend, harass, or in any way discriminate against an employee in 

the terms and conditions of employment because the employee reported conduct that 

the employee reasonably believed violated the federal securities laws. Dodd-Frank also 

created a private right of action that gives whistleblowers the right to file a retaliation 

complaint in federal court. To date, the Commission has brought three anti-retaliation 

enforcement actions, including one in FY 2017.

Exchange Act Rule 21F-17(a) prohibits any person from taking any action to 

prevent an individual from contacting the SEC directly to report a possible securities 

law violation. The Rule states that “[n]o person may take any action to impede 

an individual from communicating directly with the Commission staff about a 

possible securities law violation, including enforcing, or threatening to enforce, a 

confidentiality agreement ... with respect to such communications.”39 To date, 

the Commission has brought nine enforcement actions involving violations of 

Rule 21F-17, including four in FY 2017.

OWB supported the enforcement of whistleblower protections in FY 2017 by 

reviewing fact patterns of retaliation and attempts to impede free communications 

with the SEC, and served as subject matter experts to staff as needed on investigations.

Enforcement of Whistleblower Protections 

During FY 2017, the Commission found that a company violated Rule 21F-17 

through its efforts to determine the existence and identity of a presumed whistleblower.

On January 19, 2017, the Commission announced that Seattle-based financial services 

company HomeStreet, Inc. had agreed, without admitting or denying the Commission’s 

findings, to settle charges that it conducted improper hedge accounting and later took 

steps to impede potential whistleblowers.

40 The SEC’s order found that after the SEC 

contacted the company in April 2015 seeking documents related to hedge accounting, 

HomeStreet presumed it was in response to a whistleblower complaint and began 

taking actions to determine the identity of the whistleblower, including asking certain 

individuals to affirm that they were not the whistleblower. The company went so far to 

suggest to a presumed whistleblower that the terms of an indemnification agreement 

could allow HomeStreet to deny payment for any legal costs incurred as a witness 

during the SEC’s investigation if this person was an SEC whistleblower. HomeStreet 

also required former employees to sign severance agreements requiring them to waive 

potential whistleblower awards or risk losing their severance payments and other 

post-employment benefits. Without admitting or denying the Commission’s Rule 

“OWB supported 

the enforcement 

of whistleblower 

protections in FY 2017 

by reviewing fact 

patterns of retaliation 

and attempts to

impede free 

communications with 

the SEC . . .”

38 15 U.S.C. § 78u-6(h)(1).

39 17 C.F.R. § 240.21F-17(a).

40 In the Matter of HomeStreet, Inc. and Darrell Van Amen, Exchange Act Rel. No. 79844, File No. 3-17801 

(Jan. 19, 2017).
20 | U.S. SECURITIES AND EXCHANGE COMMISSION

21F-17 finding, HomeStreet agreed to make reasonable efforts to contact former 

company employees who signed the Rule 21F-17-violative severance agreements, and 

provide them with a link to the Commission’s order and a statement that HomeStreet 

does not prohibit former employees from reporting information to the Commission or 

from seeking and obtaining a whistleblower award from the Commission. HomeStreet 

additionally agreed to pay a civil money penalty of $500,000 to the Commission.

The Commission also brought two actions against companies for using language 

in separation and severance agreements that specifically targeted the Commission’s 

whistleblower rules and incentives. In the first action, brought on December 19, 2016, 

the Commission announced that Virginia-based technology company NeuStar, Inc.

had agreed to settle charges involving severance agreements that impeded at least one 

former employee from communicating information to the SEC.

41 The Commission’s 

order found that NeuStar, Inc. had violated Exchange Act Rule 21F-17 by routinely 

entering into severance agreements that forbade former employees from engaging in 

communications that disparaged the company with the SEC, among other regulators.

Former employees could be compelled to forfeit all but $100 of their severance pay 

for breaching the clause. NeuStar used these severance agreements with at least 246 

departing employees from August 12, 2011 to May 21, 2015. NeuStar voluntarily 

revised its severance agreements promptly after the SEC began investigating. The 

company agreed to make reasonable efforts to inform those who signed the severance 

agreements that NeuStar does not prohibit former employees from communicating 

any concerns about potential violations of law or regulation to the SEC. Without 

admitting or denying the SEC’s Rule 21F-17 findings, NeuStar also agreed to pay a 

civil money penalty of $180,000 to the Commission.

The second action was brought against BlackRock, Inc. for using impermissible 

language in its separation agreements. The Commission’s order found that BlackRock 

violated Rule 21F-17 because over 1,000 departing BlackRock employees had signed 

separation agreements containing violative language stating that they “waive any right 

to recovery of incentives for reporting of misconduct, including, without limitation, 

under the Dodd-Frank Wall Street Reform and Consumer Protection Act” in exchange 

for receiving monetary separation payments from the firm. BlackRock added the waiver 

provision in October 2011 after the SEC adopted Rule 21F-17, and the firm continued 

using it in its separation agreements until March 2016. Without admitting or denying 

the Commission’s Rule 21F-17 finding, BlackRock agreed to pay a $340,000 penalty to 

settle the charges.

42

Finally, in FY 2017, the SEC brought an action against a company for violation of both 

Rule 21F-17 and the whistleblower anti-retaliation provisions of Section 21F(h). On 

December 20, 2016, the Commission announced an action against SandRidge Energy, 

Inc. This Oklahoma-based oil and gas company agreed to settle charges that it violated 

Section 21F(h) of the Exchange Act when it terminated a whistleblower in retaliation 

for expressing concerns internally about how the company calculated its oil and gas 

reserves.

43 The SEC’s order also found that from August 2011 through April 2015, 

SandRidge had entered into separation agreements that did not permit employees to 

41 In the Matter of NeuStar, Inc., Exchange Act Rel. No. 79593, File No. 3-17736 (Dec. 19, 2016).

42 In the Matter of BlackRock, Inc., Exchange Act Rel. No. 79804, File No. 3-17786 (Jan. 17, 2017).

43 In the Matter of SandRidge Energy, Inc., Exchange Act Rel. No. 79607, File No. 3-17739 (Dec. 20, 2016).
WHISTLEBLOWER PROGRAM | 21

voluntarily cooperate with any governmental agency in connection with any complaint 

or investigation of the company. The order found that SandRidge had conducted 

multiple reviews of its separation agreements after Rule 21F-17 became effective in 

August 2011, yet continued to regularly use restrictive language prohibiting outgoing 

employees from participating in any government investigation or disclosing information 

potentially harmful or embarrassing to the company. More than 500 former employees 

signed agreements with the restrictive language. Without admitting or denying the SEC’s 

Rule 21F-17 and retaliation findings, SandRidge agreed to pay a penalty of $1.4 million.

Protection for Internal Reporting

When the Commission issued the Whistleblower Rules in 2011, it stated that the 

Dodd-Frank employment retaliation protections apply not only when individuals 

report potential securities law violations directly to the SEC but also when they, 

among other things, report internally to their employer, like the whistleblower 

in the SandRidge Energy matter.

44 In August 2015, the Commission released 

interpretive guidance clarifying the interaction of the anti-retaliation provisions 

and the award provisions of the Whistleblower Rules with respect to the protection 

of internal reporting under the Dodd-Frank Act. As explained in the interpretive 

guidance, individuals can report possible securities law violations internally, 

through their companies’ respective reporting structures, and still be protected if 

they then suffer adverse employment consequences—even if they have not reported 

such information to the SEC in the manner required to qualify for an award under 

the Whistleblower Rules.

45

The Commission has filed several amicus curiae briefs in support of whistleblowers in 

private retaliation lawsuits in district and appellate courts urging the courts to defer to 

the Commission’s rule that individuals are entitled to employment retaliation protection 

if they report information of a possible securities violation internally at a publicly-traded 

company, regardless of whether they have separately reported the information to the 

SEC.

46 As the SEC has explained in these amicus filings, ensuring that employees are 

protected from employment retaliation whenever they report possible securities law 

violations, whether internally or to the SEC, is critical to the SEC’s enforcement efforts.

Put simply, if individuals are not assured they will be protected from retaliation if they 

report internally, they will be less likely to report internally, which could undermine 

the important role that internal compliance programs play in helping the Commission 

prevent, detect, and stop securities law violations.

44 17 C.F.R. § 240.21F-2(b)(1). The anti-retaliation protections apply whether or not the individual satisfies 

the requirements to qualify for an award. Id. § 240.21F-2(b)(1)(ii).

45 The SEC’s interpretive guidance may be found on OWB’s webpage, www.sec.gov/whistleblower/retaliation, and 

also has been published in the Federal Register at 80 Fed. Reg. 47,829 (Aug. 10, 2015).

46 See Danon v. Vanguard Grp., Inc., 686 F. App’x 101 (3d Cir. 2017) (amicus filed Oct. 26, 2016); Duke v. 

Prestige Cruises Int’l, Inc., No. 16-15426 (11th Cir., amicus filed Jan. 31, 2017); Deykes v. Cooper-Standard 

Auto., Inc., No. 16-2740 (6th Cir. July 17, 2017) (amicus filed Feb. 22, 2017); Verfuerth v. Orion Energy 

Sys., Inc., No. 16-3502 (7th Cir., amicus filed May 5, 2017); see also, e.g., Somers v. Digital Realty Trust, 

Inc., 850 F.3d 1045 (9th Cir. 2017) (amicus filed May 25, 2016); Verble v. Morgan Stanley Smith Barney 

LLC, 676 F. App’x 421 (6th Cir. 2017) (amicus filed Feb. 1, 2016); Beacom v. Oracle Am., Inc., 825 F.3d 

376 (8th Cir. 2016) (amicus filed Aug. 19, 2015); Berman v. Neo@Ogilvy LLC, 801 F.3d 145 (2d Cir. 2015) 

(amicus filed Feb. 6, 2015); Safarian v. Am. DG Energy, Inc., 622 F. App’x 149 (3d Cir. 2015) (amicus filed 

Dec. 11, 2014); Liu Meng-Lin v. Siemens AG, 763 F.3d 175 (2d Cir. 2014) (amicus filed Feb. 20, 2014); 

Sandford Wadler v. Bio-rad Labs., Inc., 141 F. Supp. 3d 1005 (N.D. Cal. 2015) (amicus filed Dec. 13, 2016); 

Stroh v. Saturna Capital Corp., 16-cv-00283-TSZ (W.D. Wash. Aug. 4, 2016) (amicus filed May 20, 2016); 

Davies v. Broadcom Corp., 130 F. Supp. 3d 1343 (C.D. Cal. 2015) (amicus filed Sept. 8, 2015); Wiggins v. 

ING U.S., Inc., 2015 WL 3771646 (D. Conn. June 17, 2015) (amicus filed June 16, 2015).
22 | U.S. SECURITIES AND EXCHANGE COMMISSION

The federal courts of appeals are divided over whether the Dodd-Frank anti-retaliation 

protections apply to employees who report potential violations of the securities laws 

internally without also reporting directly to the Commission. Most recently, in Somers v.

Digital Realty Trust, Inc., the United States Court of Appeals for the Ninth Circuit 

agreed with the United States Court of Appeals for the Second Circuit’s decision 

in Berman v. Neo@Ogilvy LLC by finding that Congress did not intend to limit 

protections to those who disclose information to the SEC.

47 Rather, the anti-retaliation 

provision also protects those who were fired or otherwise retaliated against after making 

internal disclosures of alleged unlawful activity under the Sarbanes-Oxley Act and other 

laws, rules, and regulations. The Ninth Circuit agreed with the Second Circuit that even 

if the statute were ambiguous, the SEC’s regulation resolved any ambiguity, and was 

entitled to deference. The United States Court of Appeals for the Fifth Circuit in Asadi v. 

G.E. Energy (USA), L.L.C.,

48 however, found to the contrary.

On June 26, 2017, on the basis of the circuit split, the United States Supreme Court 

granted certiorari in Digital Realty Trust, Inc. v. Somers to address the scope of 

Dodd-Frank’s anti-retaliation protections.

49 On October 17, 2017, the United States 

Solicitor General, acting on behalf of the Department of Justice and joined by the 

Commission, filed an amicus curiae brief in the Supreme Court in support of the 

whistleblower-respondent. The United States’ amicus curiae brief in support of the 

whistleblower in Digital Realty continues the Commission’s advocacy efforts and urges 

the Supreme Court to recognize that Dodd-Frank’s statutory language, its legislative 

history, and the Commission’s rules require that individuals who internally report 

potential securities violations at a publicly-traded company are entitled to employment 

retaliation protection, regardless of whether they have separately reported that 

information to the Commission.

47 850 F.3d 1045 (9th Cir. 2017) (agreeing with Berman, 801 F.3d 145, 155 (2d Cir. 2015)).

48 720 F.3d 620, 621 (5th Cir. 2013).

49 137 S. Ct. 2300 (U.S. June 26, 2016) (No. 16-1276).
WHISTLEBLOWER PROGRAM | 23

W H I S T L E B LOW E R T I P S R E C E I V E D 

The Whistleblower Rules specify that individuals who would like to be part of the 

whistleblower program must submit their tips via the Commission’s online portal 

or by mailing or faxing their tips on Form TCR to OWB.

50 Whistleblowers who use 

the online portal to submit a complaint receive a computer-generated confirmation 

of receipt with a TCR submission number. For those who submit a hard-copy Form 

TCR by mail or fax, OWB sends an acknowledgement letter, which includes a TCR 

submission number, or a deficiency letter explaining that the information was not 

properly submitted under the Whistleblower Rules. All whistleblower tips related to 

potential securities law violations received by the Commission are entered into the TCR 

System and are evaluated by the Commission’s Office of Market Intelligence within the 

Division of Enforcement.

Increase in Whistleblower Tips

Across the history of the whistleblower program, the Commission’s receipt of 

whistleblower tips has reflected an upward trajectory. Since August 2011, the 

Commission has received over 22,000 whistleblower tips, and in FY 2017 alone, 

received more than 4,400 tips. The table below shows the number of whistleblower 

tips received by the Commission on a yearly basis since the inception of the 

whistleblower program51:

FY2011 FY2012 FY2013 FY2014 FY2015 FY2016 FY2017

334 3,001 3,238 3,620 3,923 4,218 4,484

As reflected in this table, from FY 2012, the first year for which we have full-year data, 

to FY 2017, the number of whistleblower tips received by the Commission has grown 

by almost 50 percent.

“Across the history 

of the whistleblower 

program, the 

Commission’s receipt 

of whistleblower 

tips has reflected an 

upward trajectory. ”

50 17 C.F.R. § 240.21F-9(a).

51 The Commission also receives tips from individuals who do not wish, or are not eligible, to be considered 

for an award under the whistleblower program. The data in this report is limited to those TCRs that 

include the required whistleblower declaration and does not reflect all tips or complaints received by the 

Commission during the fiscal year.

Because the Whistleblower Rules became effective on August 12, 2011, only seven weeks of 

whistleblower data was available for FY 2011.

For FY 2016 and 2017, the Commission received an unusually high number of whistleblower tips from 

two individuals. The data for FY 2016 and 2017 excludes tips received from these two individuals—both 

in this section of the report and in the appendices to this report.
24 | U.S. SECURITIES AND EXCHANGE COMMISSION

Whistleblower Allegation Type

Whether submitting their tips on Form TCR or through the online portal, whistleblowers 

are asked to identify the nature of their complaint allegations. For FY 2017, the most 

common complaint categories reported by whistleblowers were 19 percent Corporate 

Disclosures and Financials, 18 percent Offering Fraud, and 12 percent Manipulation.

52

The following graph reflects the number of whistleblower tips received in FY 2017 by 

allegation type53:

Trading and

Pricing

Offering

Fraud

Not

Reported

Municipal

Securities and 

Public Pension

FCPA

0

200

400

600

800

1000

1200

Corporate 

Disclosures 

and Financials

Manipulation Insider

Trading

Unregistered

Offerings

Market Other*

Event

954

210

231

468

125

67

94

758

1,162

271

144

52 This breakdown reflects the categories selected by whistleblowers and, thus, the data represents the 

whistleblower’s own characterization of the violation type.

53 The category of “Other” indicates that the submitter identified the whistleblower TCR as not fitting into 

any allegation category that is listed on the questionnaire.
WHISTLEBLOWER PROGRAM | 25

The type of securities violations reported by whistleblowers has remained generally 

consistent over the last six years. Since the beginning of the program, Corporate 

Disclosures and Financials, Offering Fraud, and Manipulation have consistently ranked 

as the three highest allegation types reported by whistleblowers. Appendix A to this 

report provides a comparison among the number of whistleblower tips by allegation 

type that the Commission received during FY 2014 through 2017.

Geographic Origin of Whistleblower Tips

Through OWB’s extensive outreach efforts to publicize and promote the Commission’s 

whistleblower program, the Commission continues to receive whistleblower 

submissions from individuals throughout the United States, as well as internationally.

During FY 2017, California, New York, Texas, Florida, and New Jersey yielded the 

highest number of whistleblower tips.

FREQUENCY

0–20

21–40

41–60

61–100

>101
26 | U.S. SECURITIES AND EXCHANGE COMMISSION

Since the beginning of the whistleblower program, the Commission has received 

whistleblower tips from individuals in 114 countries outside the United States. In 

FY 2017 alone, the Commission received whistleblower submissions from individuals 

in 72 foreign countries. After the United States, OWB received the highest number of 

whistleblower tips in FY 2017 from individuals in the United Kingdom, Canada, and 

Australia. The map below reflects all countries in which whistleblower tips originated 

during FY 2017.

Appendices B and C to this report provide detailed information concerning the sources 

of domestic and foreign whistleblower tips that the Commission received during 

FY 2017.
WHISTLEBLOWER PROGRAM | 27

P R O C E S S I N G O F W H I S T L E B LOW E R T I P S 

The Office of Market Intelligence (OMI), within the Commission’s Division of 

Enforcement, evaluates incoming whistleblower TCRs and assigns specific, credible, and 

timely TCRs to members of the Commission staff for further investigation or analysis.

TCR Evaluation 

OMI reviews every TCR submitted by a whistleblower to the Commission that alleges 

a possible securities law violation. During the evaluation process, OMI staff examines 

each tip to identify those with high-quality information that warrant the additional 

allocation of Commission resources. Generally, when the evaluation of a tip could 

benefit from the specific expertise of another Division or Office within the SEC, the 

tip is forwarded to staff in that Division or Office for further analysis. When OMI 

determines that a tip warrants further review, OMI staff assigns the complaint to one 

of the Commission’s eleven regional offices, a specialty unit, or to an Enforcement 

group in the Home Office. Complaints that relate to an existing investigation are 

forwarded to the staff working on the matter.

The Commission may use information from whistleblower tips and complaints in 

several different ways. For example, the Commission may initiate an enforcement 

investigation based on the whistleblower’s tip. Even if the tip does not cause an 

investigation to be opened, it may still help lead to a successful enforcement action if 

the whistleblower provides additional information that significantly contributes to an 

ongoing or active investigation. Tips may also prompt the Commission to commence 

an examination of a regulated entity, which may lead to an enforcement action or to 

the entity correcting the problem or clarifying an issue.

As noted previously, OWB actively tracks whistleblower tips that are referred to 

Enforcement staff for investigation. OWB currently is tracking over 700 matters 

in which a whistleblower’s tip has caused a Matter Under Inquiry or investigation 

to be opened or which have been forwarded to Enforcement staff for review and 

consideration in connection with an ongoing investigation. However, not all of these 

matters will result in an enforcement action, or an enforcement action where the 

required threshold of over $1 million in monetary sanctions will be ordered.

In general, the more specific, credible, and timely a whistleblower tip, the more 

likely it is that the tip will be forwarded to investigative staff for further follow-up 

or investigation. For instance, if the tip identifies individuals involved in the scheme, 

provides examples of particular fraudulent transactions, or points to non-public 

materials evidencing the fraud, the tip is more likely to be assigned to Enforcement 

staff for investigation. Tips that make blanket assertions or general inferences based on 

market events, or which do not relate to the federal securities laws, are less likely to be 

forwarded to or investigated by Enforcement staff.

In certain instances, OMI may determine it is more appropriate that a whistleblower’s 

tip be investigated by another regulatory or law enforcement agency. When this 

occurs, OMI refers the tip to the other agency in accordance with the Exchange Act’s 

whistleblower confidentiality requirements.

“ In general, 

the more specific, 

credible, and timely 

a whistleblower tip, 

the more likely it 

is that the tip will 

be forwarded to 

investigative staff 

for further follow-up 

or investigation.”
28 | U.S. SECURITIES AND EXCHANGE COMMISSION

Tips that relate to the financial affairs of an individual investor or a discrete 

investor group usually are forwarded to the Commission’s Office of Investor 

Education and Advocacy (OIEA) for resolution. Comments or questions about 

agency practice or the federal securities laws also are forwarded to OIEA.

Assistance by OWB

OWB supports the tip allocation and investigative processes in several ways. When 

whistleblowers submit tips on a Form TCR in hard-copy by mail or fax, OWB enters 

the information into the TCR System so it can be evaluated by OMI. Tips submitted by 

whistleblowers through the Commission’s online portal are automatically forwarded to 

OMI for evaluation. During the evaluation process, OWB may assist by contacting the 

whistleblower to obtain additional information to help in the triage process.

After submitting an initial tip, a whistleblower is free to, and often does, submit 

additional information or materials to buttress his or her earlier allegations. Ideally, 

additional information is sent to OWB in hard-copy by mail or fax and includes the 

original TCR submission number. OWB then uploads the additional information into 

the TCR System and sends an acknowledgement letter to the whistleblower confirming 

receipt of the information or materials. Additional information can also be submitted 

via the portal, but reference should be made to the original TCR submission number.
WHISTLEBLOWER PROGRAM | 29

S E C U R I T I E S A N D E XC H A N G E C O M M I S S I O N 

INVESTOR PROTECTION FUND

Section 922 of the Dodd-Frank Act established the Investor Protection Fund to 

provide funding for the Commission’s whistleblower award program, including the 

payment of awards in related actions.

54 As required by statute, all payments are 

made out of this Fund, which is financed entirely through monetary sanctions paid 

to the SEC by securities law violators. No money has been taken or withheld from 

harmed investors to pay whistleblower awards. The Fund also is used to finance 

the operations of the suggestion program of the SEC’s Office of Inspector General.

55

The suggestion program is intended for the receipt of suggestions from Commission 

employees for improvements in work efficiency, effectiveness, productivity, and the 

use of resources at the Commission, as well as allegations by Commission employees 

of waste, abuse, misconduct, or mismanagement within the Commission, and is 

operated outside of OWB.

56

Section 21F(g)(5) of the Exchange Act requires certain Fund information to be reported 

to Congress on an annual basis. Below is a chart containing Fund-related information 

for FY 2017.

 FY 2017

Balance of Fund at beginning of fiscal year $ 368,116,007.44

Amounts deposited into or credited to Fund during fiscal year $ 0.0057

Amount of earnings on investments during fiscal year $ 2,734,295.64

Amount paid from Fund during fiscal year to whistleblowers $ (49,041,304.95)

Amount disbursed to Office of the Inspector General during 

fiscal year

$ (129,324.76)

Balance of Fund at end of the fiscal year $ 321,679,673.37

In addition, Section 21F(g)(5) of the Exchange Act requires a complete set of 

audited financial statements for the Fund, including a balance sheet, income sheet, 

income statement, and cash-flow analysis. That information will be included in the 

Commission’s Agency Financial Report, which will be separately submitted to Congress.

54 Section 21F(g)(2)(A) of the Exchange Act, 15 U.S.C. § 78u-6(g)(2)(A).

55 Section 21F(g)(2)(B) of the Exchange Act, 15 U.S.C. § 78u-6(g)(2)(B), provides that the Fund shall be 

available to the Commission for “funding the activities of the Inspector General of the Commission under 

section 4(i).” The Commission’s Office of General Counsel has interpreted this section to refer to Exchange 

Act Section 4D, which established the Inspector General’s suggestion program. That section provides 

that the “activities of the Inspector General under this subsection shall be funded by the Securities and 

Exchange Commission Investor Protection Fund established under Section 21F.” Id. § 78d-4(e).

56 Section 4D(a) of the Exchange Act, id. § 78d-4(a).

57 Pursuant to Section 21F(g)(3) of the Exchange Act, no monetary sanctions are deposited into or credited 

to the Fund if the balance of the Fund exceeds certain thresholds at the time the monetary sanctions are 

collected. Id. § 78u-6(g)(3).

WHISTLEBLOWER PROGRAM | 31

APPENDIX A

W H I S T L E B LOW E R T I P S B Y A L L E G AT I O N T Y P E 

COMPARISON OF FISCAL YEARS 2014–2017

0

300

600

900

1200

2014

2015

2016

2017

Corporate 

Disclosures 

and Financials

Offering

Fraud

Manipulation Insider

Trading

Trading and

Pricing

FCPA Unregistered

Offerings

Market

Event

Municipal

Securities and 

Public Pension

Other* Not Reported

97 97 94

114

911

956

58 57

139

192

102

150 159

186

210

144

213

256

273

563

482

581

610 613

687

938

954

472 468

262

231

257 271

238

143 144

102

125

67 67

996

1,162

646

758

*The category of “Other” indicates that the submitter identified the whistleblower TCR as not fitting into any allegation category that is listed on the questionnaire.
32 | U.S. SECURITIES AND EXCHANGE COMMISSION

APPENDIX B

W H I ST L E B LOW E R T I P S R E C E I V E D BY G E O G R A P H I C LO C AT I O N 

UNITED STATES AND ITS TERRITORIES, FISCAL YEAR 2017*

AK

AL

AR

AZ

CA

CO

CT

DC

DE

FL

GA

HI

IA

ID

IL

IN

KS

KY

LA

MA

MD

ME

MI

MN

MO

MS

MT

NC

ND

NE

NH

NJ

NM

NV

NY

OH

OK

OR

PA

RI

SC

SD

TN

TX

UT

VA

VT

WA

WI

WV

WY

0 100 200 300 400 500 600

54 

229

151

71

71

87

73

55

32

80

175

438 

37

114

4

250

30

133

76

61

28

11

14

3

15

9

28

10

6

15

14

15

13

11

28

6

9

7

1

6

3

2

18

36

21

7

33

34

33

27

500

*Multiple individuals may jointly submit a TCR under the Commission’s whistleblower program. Appendix B reflects the number of individuals submitting 

WB TCRs to the Commission within the United States, or one of its territories, and not the total number of domestic WB TCRs received by the Commission 

during FY 2017. For example, a WB TCR that is jointly submitted by two individuals—one in New York and one in New Jersey—would be reflected in 

Appendix B as a submission from both New York and New Jersey. The total number of individuals submitting WB TCRs in the United States or a U.S. 

territory during FY 2017 exceeded 3,100 and constituted about 68 percent of the individuals participating in the Commission’s whistleblower program for 

this period. Additionally, over 900 individuals, constituting approximately 20 percent of the total number of persons participating in the Commission’s 

whistleblower program in FY 2017, submitted WB TCRs without any foreign or domestic geographical categorization or submitted them anonymously 

through counsel.
WHISTLEBLOWER PROGRAM | 33

APPENDIX C

W H I ST L E B LOW E R T I P S R E C E I V E D BY G E O G R A P H I C LO C AT I O N 

INTERNATIONAL, FISCAL YEAR 2017*

ANDORRA, PRINCIPALITY OF

ARGENTINA

AUSTRALIA

AUSTRIA

AZERBAIJAN

BELGIUM

BRAZIL

BULGARIA

CANADA

CHILE

CHINA, PEOPLE'S REPUBLIC OF

COLOMBIA

COSTA RICA

CZECH REPUBLIC

DEMOCRATIC REPUBLIC OF CONGO

DENMARK

EGYPT

ESTONIA

FINLAND

FRANCE

FRENCH POLYNESIA

GERMANY

GHANA

GREECE

GUATEMALA

HONG KONG

INDIA

INDONESIA

IRAN

IRELAND

ISRAEL

ITALY

JAPAN

KAZAKHSTAN

LUXEMBOURG

MACAU

MADAGASCAR

MALAYSIA

MALTA

MEXICO

MONTENEGRO

MOROCCO

NETHERLANDS

NEW ZEALAND

NIGERIA

NORWAY

OMAN

PAKISTAN

PANAMA

PAPUA NEW GUINEA

PHILIPPINES

POLAND

PORTUGAL

QATAR

RUSSIA

SAINT LUCIA

SAUDI ARABIA

SENEGAL

SINGAPORE

SOUTH AFRICA

SOUTH KOREA

SPAIN

SWEDEN

SWITZERLAND

TAIWAN

THAILAND

TUNISIA

TURKEY

UKRAINE

UNITED ARAB EMIRATES

UNITED KINGDOM

VENEZUELA

1

5

48

1

1

10

6

73

1

2

7

19

1

14

2

2

1

1

1

26

26

1

1

4

3

1

1

1

11

1

1

1

84

1

2

21

39

3

1

3

1

1

2

2

1

1

23

12

5

7

3

1

2

2

6

2

1

5

3

3

1

1

1

2

6

12

1

10

10

3

3

7

0 20 40 60 80 100

*As with domestic WB TCRs, multiple individuals from abroad may jointly submit a TCR under the Commission’s whistleblower program. Appendix C 

reflects the number of individuals submitting WB TCRs to the Commission from abroad, and not the total number of foreign WB TCRs received during 

FY 2017. The number of individuals submitting WB TCRs from abroad during FY 2017 exceeded 550, and constituted approximately 12 percent of the 

individuals participating in the Commission’s whistleblower program.
OFFICE OF THE WHISTLEBLOWER

Washington, DC