2020 ANNUAL REPORT TO CONGRESS 

Whistleblower

 Program 

U.S. SECURITIES AND EXCHANGE COMMISSION 
DISCLAIMER

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

and Exchange Commission. Th ange Commission. Th ange Commission. The Commission e Commission

has expressed no vessed no vessed no view regarding the analysis,

findings, or conclusions cont indings, or conclusions cont indings, 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 Offce of the Whistleblower ...............1 

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

Activities of the Offce of the Whistleblower ...........................6 

Claims for Awards ...............................................9 

Whistleblower Awards Made in Fiscal Year 2020 ................ 9 

Rule 21F-6 Factors in Fiscal Year 2020 Awards................. 17 

Overview of Award Process ................................ 19 

Profles of Award Recipients.......................................24 

Preserving Individuals’ Rights to Report to the Commission and 

Shielding Employees from Retaliation ...............................26 

Whistleblower Tips Received ......................................27 

Number of Whistleblower Tips ............................. 27 

Whistleblower Allegation Type ............................. 28 

Geographic Origin of Whistleblower Tips ..................... 29 

Processing of Whistleblower Tips...................................31 

Intake of Hard-Copy Form TCRs ........................... 31 

TCR Evaluation......................................... 31 

Amendments to Whistleblower Rules ...............................33 

Securities and Exchange Commission Investor Protection Fund ...........38 

Appendix A. Whistleblower Tips by Allegation Type – Comparison of 

Fiscal Years 2017-2020...........................................40 

Appendix B. Whistleblower Tips Received by Geographic 

Location – United States and Its Territories – Fiscal Year 2020. . . . . . . . . . . .41 

Appendix C. Whistleblower Tips Received by Geographic 

Location – International – Fiscal Year 2020...........................42 

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

 

 

WHISTLEBLOWER PROGRAM | 1 

MESSAGE FROM THE CHIEF OF THE

OFFICE OF THE WHISTLEBLOWER 

Fiscal Year (FY) 2020 was a momentous year for the U.S. Securities and Exchange 

Commission’s (SEC or Commission) whistleblower program. FY 2020 not only

marked the 10-year anniversary of the inception of the whistleblower program under 

the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank), it 

also marked numerous record-breaking accomplishments in terms of individuals and

dollars awarded, claims processed, and tips received. In FY 2020, the Commission and 

its staff implemented a number of efficiencies designed to improve the claims review 

and award process, and Chairman Jay Clayton and Stephanie Avakian, Director of the 

Division of Enforcement (Enforcement), allocated additional resources to the Office of 

the Whistleblower (the Office or OWB). The Commission also adopted amendments

to the rules governing the whistleblower program to provide greater clarity to

whistleblowers and increase the program’s efficiency and transparency. 

The milestones achieved in FY 2020 for the number of claims processed, the 

amount awarded in a single fiscal year, and the number of whistleblowers awarded

are reflections of the Commission’s dedication to the program, and efforts by the

resolute and dedicated staff in OWB, in partnership with other staff in Enforcement, 

to increase efficiencies in the review and processing of award claims. We are proud that 

OWB staff, along with our colleagues across the Commission, were able to continue

operations and work effectively despite the challenges of COVID-19.

FY 2020 saw the program reach a significant milestone when the Commission

crossed over the $500 million mark in total whistleblower awards under the program. 

Whistleblowers awarded this year are diverse. They include, for example, current and 

former employees of companies who had first-hand knowledge of unlawful conduct; 

outsiders who provided detailed analysis of wrongdoing; foreign nationals who shone 

a light on hard to detect fraud happening abroad but impacting U.S. investors and the 

marketplace; and investors who lost money at the hands of fraudsters. We recognize 

and applaud the courage of these whistleblowers for stepping forward and reporting 

unlawful conduct. 

We are also gratified by the whistleblower program’s contributions to the protection

of the Main Street investor. Since the program’s inception and through the end

of FY 2020, enforcement matters brought with information from meritorious 

whistleblowers have resulted in orders for more than $2.7 billion in total monetary

sanctions, including more than $1.5 billion in disgorgement of ill-gotten gains and 

interest, of which more than $850 million has been, or is scheduled to be, returned 

to harmed investors. Several of the awards made in FY 2020 were to whistleblowers 

who provided information that helped the Commission detect and stop harm to retail

investors. For example, in September 2020, the Commission awarded nearly $30

million to two whistleblowers whose information allowed the agency to return tens 

of millions of dollars to harmed retail investors.1 

“FY 2020 . . .

marked numerous 

record-breaking 

accomplishments in 

terms of individuals 

and dollars awarded, 

claims processed, and 

tips received.” 

Order Determining Whistleblower Award, Exchange Act Release No. 90049, File No. 2020-36 (Sept. 30, 

2020). 

1 
2 | U.S. SECURITIES AND EXCHANGE COMMISSION 

“In FY 2020, the

Commission awarded 

approximately 

$175 million to 39 

individuals — both the 

highest dollar amount 

and the highest 

number of individuals 

awarded in a given 

fscal year.” 

Record-Breaking Awards Paid and Claims Processed in FY 2020 

In FY 2020, the Commission awarded approximately $175 million to 39 individuals

— both the highest dollar amount and the highest number of individuals awarded in a

given fiscal year. We are particularly proud of the number of individuals awarded under

the program this fiscal year, which is triple the number awarded in 2018, the nexthighest fiscal year, when the Commission awarded 13 individuals. 

Since issuing its first award in 2012 through the end of FY 2020, the Commission has 

awarded approximately $562 million to 106 individuals. The awards made in FY 

2020 represent 31% of the total dollars awarded to all whistleblowers and 37% of 

the individual award recipients since the beginning of the program. The awards made 

in FY 2020 include a nearly $50 million award — the then largest amount ever 

awarded to one individual under the program.2 

In FY 2020, OWB processed more claims than in any other year of the program, 

and the Commission issued the largest number of Final Orders resolving whistleblower

award claims, including both award and denial orders, in a fiscal year. The Commission 

issued Final Orders for 197 individual award claims in FY 2020, representing a 

140% increase from FY 2019. In addition, OWB processed 315 claims to Preliminary

Determination. This is the largest number of Preliminary Determinations issued in a 

fiscal year, representing a 167% increase from FY 2019.3It is anticipated that the rule 

amendments adopted by the Commission will provide additional efficiencies in claims 

processing for years to come. 

Record-Breaking Number of Whistleblower Tips Received in Fiscal Year 2020 

In addition to reaching milestones in dollars awarded and the processing of award

claims, the Commission also received the highest number of whistleblower tips in a

fiscal year. In FY 2020, the Commission received over 6,900 whistleblower tips—a 

31% increase from FY 2018, the second highest tip year, and a 130% increase since the 

beginning of the program. The third quarter of FY 2020 (April-June) resulted in a 

particularly high number of whistleblower tips. As in prior fiscal years, tips received this

fiscal year hailed from a variety of geographic origins, both domestic and foreign. The 

Commission received tips from individuals in 78 foreign countries, as well as from every

state in the United States.

OWB also staffs a public hotline to answer questions from whistleblowers and the 

general public concerning the whistleblower program or how to submit information to 

the Commission. In FY 2020, OWB staff returned over 2,850 calls to the public. Since

the hotline was established, the Office has returned nearly 26,900 calls responding to

questions about the program.

2 On October 22, 2020, after the end of FY 2020, the Commission issued the largest award to date 

under the program when it granted a $114 million award to a whistleblower. See Order Determining 

Whistleblower Award Claim, Exchange Act Rel. No. 90247, File No. 2021-2 (Oct. 22, 2020). 

3 A Preliminary Determination and a Final Order could be issued for the same award claim in a fscal year. 
WHISTLEBLOWER PROGRAM | 3 

Notable Enforcement Action in Whistleblower Protections 

In FY 2020, the Commission filed an amended complaint in SEC v. Collector’s 

Coffee, Inc.4 to include a Rule 21F-17 charge against the defendants for impeding 

the efforts of harmed investors to report misconduct to the Commission. According 

to the allegations in the amended complaint, after the investors sued the defendants, 

defendants entered into a settlement agreement with the investors that expressly 

prohibited the investors from speaking to the Commission about their claims. The 

amended complaint further alleges the defendants went so far as to sue two investors 

that they believed breached one of the settlement agreements. The action remains 

pending in federal court in New York. 

Supporting investigations into retaliation and attempts to impede reporting continues to 

be a high priority for the Office to ensure that whistleblowers feel comfortable and safe 

“FY 2020 truly 

reporting to the SEC without fear of reprisal. 

Whistleblower Rule Amendments was a historic year 

In FY 2020, the Commission adopted Whistleblower Rule amendments, which 

were proposed in June 2018. The rule amendments are intended to provide greater 

transparency, efficiency and clarity, and to strengthen and bolster the program in several that demonstrated 

ways. The rule amendments increase efficiencies around the review and processing 

of whistleblower award claims, and provide the Commission with additional tools in 

making whistleblower awards to appropriately reward meritorious whistleblowers the Commission’s 

for their efforts and contributions to a successful enforcement action. A more fulsome 

discussion of the rule amendments begins on page 33. dedication to the 

FY 2020 truly was a historic year that demonstrated the Commission’s dedication 

to the whistleblower program, which continues to have a significant impact on the whistleblower Commission’s enforcement efforts and protection of retail investors. We hope the 

awards made in FY 2020 continue to incentivize whistleblowers to come forward 

and report specific, timely, and credible information to the Commission, which in program. . . .” 

turn enhances the agency’s ability to detect wrongdoing and protect investors and the 

marketplace. 

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

federal securities law violation to expeditiously submit a tip via the Commission’s online 

portal (www.sec.gov/whistleblower). 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. 

JANE NORBERG 

Chief, Offce of the Whistleblower 

November 16, 2020 

Amended Complaint & Demand for Jury Trial, U.S. Sec. & Exch. Comm’n v. Collector’s Coffee, Inc. 

(d/b/a Collectors Café) & Mykalai Kontilai, No. 19-cv-04355-LGS-GWG (S.D.N.Y. Nov. 4, 2019). 

4 
4 | U.S. SECURITIES AND EXCHANGE COMMISSION 

HISTORY AND PURPOSE 

Dodd-Frank5 amended the Securities Exchange Act of 1934 (Exchange Act)6 by, among 

other things, adopting Section 21F,7 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.8 

Awards must be made in an amount that is 10 percent or more and 30 percent or less 

“It is OWB’s mission of the monetary sanctions collected.9

 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 to protect investors eligible whistleblowers are paid. 

The Commission established OWB, an office within Enforcement, to administer and by administering an effectuate the whistleblower program. It is OWB’s mission to protect investors by 

administering an efficient, high-quality whistleblower program that is responsive to 

whistleblower needs and helps the Commission identify and stop securities fraud. efcient, high-quality 

In addition to establishing an awards program to encourage the submission of highquality information, Dodd-Frank and the Commission’s Whistleblower Rules10 also whistleblower program establish confidentiality protections for whistleblower submissions,11 including the 

ability to file a whistleblower tip anonymously with the assistance of an attorney. 

that is responsive to Employers are prohibited from retaliating against whistleblowers for providing 

information to the Commission.12 

whistleblower needs and Section 924(d) of Dodd-Frank requires OWB to report annually to Congress

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

Commission to such complaints.13 In addition, Section 21F(g)(5) of the Exchange Act

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

following subjects: 

identify and stop 

securities fraud.” 

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

6 15 U.S.C. § 78a, et seq. 

7 Id. § 78u-6. 

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

9 15 U.S.C. § 78u-6(b)(1). 

10 17 C.F.R. §§ 240.21F-1 through 21F-17. 

11 Id. § 240.21F-7. 

12 15 U.S.C. § 78u-6(h)(1). The Commission’s rule amendments modify the Whistleblower Rules to comport 

with the ruling in Digital Realty that an employee must report possible securities law violations to the 

Commission to qualify for protection against retaliation. See Digit. Realty Tr., Inc. v. Somers, 138 S. Ct. 

767 (2018). 

13 15 U.S.C. § 78u-7(d). 
WHISTLEBLOWER PROGRAM | 5 

• 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 fscal year;

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

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

fscal year;

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

the preceding fscal year;

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

pursuant to Section 21F(b);

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

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

statement, and cash fow analysis.14 

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

report, which covers the period October 1, 2019 through September 30, 2020, to 

satisfy the reporting requirements of Section 924(d) of Dodd-Frank 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 2020, 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 2020

primarily address the requirements of Section 21F(g)(5) of the Exchange Act. In

addition, in connection with the Whistleblower Rule amendments, to add transparency

to the administration of the whistleblower program, the Commission directed OWB,

beginning in FY 2020, to include in its annual report to Congress, in aggregated

form, an overview discussion of the factors that were present in the awards issued

throughout the fscal year, including a qualitative discussion of how the factors affected

the Commission’s determination of the award amounts.15 Pages 17 to 18 of this report

address the new requirements of amended Rule 21F-6.

14 15 U.S.C. § 78u-6(g)(5). 

15 Adopting Release, Sept. 23, 2020, at 13. 
6 | U.S. SECURITIES AND EXCHANGE COMMISSION 

ACTIVITIES OF THE OFFICE OF THE 

WHISTLEBLOWER 

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

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

Exchange Act. Jane Norberg heads the Offce as Chief of OWB. The Offce recently 

welcomed a new Assistant Director, Jonathan Carr, to the team. Jonathan, along 

with Emily Pasquinelli, are the Assistant Directors on the team. In addition to the 

management team, there are currently thirteen full time attorneys who are dedicated to 

the work of the Offce, which includes, among other things, processing award claims 

and communications with the public. OWB also currently has three attorneys assigned 

to OWB on temporary detail to support the work of the Offce. OWB’s work is also 

furthered by a number of support staff, including an accountant, paralegals, analysts, 

law clerks, and an administrative assistant. During FY 2020, OWB also received 

assistance processing award claims from several other attorneys in the Enforcement 

Division. The improved effciencies and increased temporary staffng contributed to 

OWB’s ability to process more award claims in FY 2020. Following is an overview of 

OWB’s primary responsibilities and activities over the past fscal year. 

Assessment of Award Applications 

The whistleblower program was designed, in part, to provide monetary incentives 

to individuals 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 webpage16 for every 

Commission enforcement action that results in monetary sanctions of over 

$1 million. Those individuals who have submitted whistleblower tips pursuant 

to the program’s requirements and whose information signifcantly advanced the 

particular investigation that led to the Covered Action may submit an application 

in response to a posted NoCA. 

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 

investigative staff—or who have previously contacted OWB about the posting of a 

particular Covered Action—to confrm they are aware of the posting and applicable 

deadline for submitting claims for award. 

For every claim, OWB attorneys assess the application and the eligibility of the claimant 

and confer with relevant investigative or other Commission staff to understand the 

contribution of the claimant, if any, to the success of the Covered Action. To help 

prioritize likely meritorious claims, in FY 2020, OWB dedicated two attorneys to 

reviewing likely non-meritorious claims so that the majority of OWB attorneys are able 

to focus solely on likely meritorious claims. After the effective date of the Whistleblower 

Rule amendments, OWB expects to take advantage of the new summary disposition 

process and serial submitter bar to gain further effciencies and conserve resources. 

16 www.sec.gov/whistleblower/claim-award 
WHISTLEBLOWER PROGRAM | 7 

OWB makes recommendations to the Claims Review Staff, currently comprised of 

seven senior offcers in Enforcement, as to award eligibility. Pages 9 to 23 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 this past fscal year. 

Advancing Anti-Retaliation Protections and Combating Efforts to 

Impede Reporting 

OWB identifes and monitors whistleblower complaints alleging retaliation by 

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

securities law violations. The Commission may bring an enforcement action against 

companies or individuals who violate the anti-retaliation provisions of Dodd-Frank. 

With the Supreme Court’s ruling in Digital Realty Trust, Inc. v. Somers (Digital 

Realty),17 such enforcement actions can be brought only when a whistleblower reports 

to the Commission. OWB continues to view anti-retaliation protections as a high 

priority to ensure that whistleblowers can report to the Commission without fear 

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

companies take reprisals for whistleblowing efforts that may be appropriate for 

enforcement action. 

In addition, OWB monitors reports of the usage of confdentiality, severance, and other 

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

abilities 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 from 

communicating directly with the Commission staff about a possible securities law 

violation, including enforcing, or threatening to enforce, a confdentiality agreement... 

with respect to such communications.”18 OWB continues to work with staff to identify 

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

other actions, that may violate Rule 21F-17(a). 

Intake of Whistleblower Tips 

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.19 The Commission’s Tips, 

Complaints, and Referrals Intake and Resolution System (TCR System) 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. OWB 

strongly encourages all individuals to submit their whistleblower tips and any additional 

information electronically through the Commission’s online portal, particularly in the 

current virtual environment. There are several advantages to using the online portal, 

including the fact that individuals receive an immediate acknowledgement of their 

submission along with a confrmation number. The tip is also automatically populated 

in a queue for staff who triage tips and complaints. In addition, due to the agency’s fulltime telework posture, any whistleblower tips submitted by mail should be sent to the 

“OWB continues to 

view anti-retaliation 

protections as a high 

priority to ensure 

that whistleblowers 

can report to the 

Commission without 

fear of reprisal.” 

17 138 S. Ct. 767 (2018). 

18 Id. 

19 17 C.F.R. § 240.21F-9(a). 
8 | U.S. SECURITIES AND EXCHANGE COMMISSION 

Agency’s alternative mailing address (available at https://www.sec.gov/whistleblower/ 

submit-a-tip) instead of the SEC’s Washington, DC headquarters. For greater 

effciency and quicker review, OWB strongly recommends electronic submission over 

hard-copy submission. 

For more information on the number and types of tips received, please refer to pages 

27 to 30 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. Calls to the hotline are returned by OWB attorneys generally within 

24 business hours. 

During FY 2020, the Offce returned over 2,850 phone calls from members of the 

public. Since the hotline was established, OWB has returned nearly 26,900 calls from 

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 confdentiality 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 provides a menu of options with answers to 

frequently asked questions on the voicemail hotline. 

In addition to communicating with the public through the hotline, the Offce, as 

appropriate, communicates with whistleblowers who have submitted tips, claims for 

awards, and other correspondence to OWB. 

Public Outreach and Education 

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

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

program and educate the public about the program through OWB’s webpage.20 The 

webpage contains information about the program, links to 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, including a section dedicated to 

retaliation-related issues, and answers to frequently asked questions. 

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

press releases, and other public communications. In FY 2020, OWB continued to 

participate in public engagements aimed at promoting and educating the public about 

the Commission’s whistleblower program, albeit primarily virtually. The Offce’s target 

audience generally includes potential whistleblowers, whistleblower counsel, and 

corporate compliance counsel and professionals. OWB’s Chief also participates in legal 

panels and forums with other federal agencies with similar whistleblower programs. 

20 www.sec.gov/whistleblower 
WHISTLEBLOWER PROGRAM | 9 

CLAIMS FOR AWARDS 

Whistleblower Awards Made in Fiscal Year 2020 

In FY 2020, the Commission ordered whistleblower awards of approximately $175 

million to 39 individuals, each of whom voluntarily provided original information that 

either led to the opening of an investigation or signifcantly contributed to an existing 

investigation that led to the successful enforcement action. The number of individuals 

awarded this year was three times higher as compared to the next highest fscal years 

(FY 2016 and FY 2018) when 13 individuals were awarded. The Commission also 

awarded more money in FY 2020 than in any prior year. 

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

both by Covered Action (i.e., considering all awards made within a single Covered 

Action) and by award amount from inception of the program through FY 2020. The 

awards highlighted in red were made this past fscal year. 

TOP 10 SEC WHISTLEBLOWER AWARDS 

March 2018 

September 2018 

March 2019 

June 2020 

September 2014 

September 2020 

April 2020 

August 2016 

November 2016 

April 2020 

Per Covered Action 

$83 million 

$54 million 

$50 million 

$50 million 

$30 million 

$30 million 

$27 million 

$22 million 

$20 million 

$18 million 

March 2018 

June 2020 

September 2018 

March 2019 

March 2018 

September 2014 

April 2020 

September 2020 

August 2016 

November 2016 

Per Award Amount 

$50 million 

$50 million 

$39 million 

$37 million 

$33 million 

$30 million 

$27 million 

$22 million 

$22 million 

$20 million 

From program inception to end of Fiscal Year 2020, the SEC awarded approximately $562 million to 106 individuals. 

Four of the top 10 SEC whistleblower awards per covered action and three of the top 10 

SEC whistleblower awards per award amount are from FY 2020. Below is an overview 

of the whistleblower awards made by the Commission during the past fscal year. 
10 | U.S. SECURITIES AND EXCHANGE COMMISSION 

Nearly $50 Million Awarded to Whistleblower 

On June 4, 2020, the Commission announced a nearly $50 million whistleblower award to 

an individual who provided detailed, frsthand observations of misconduct by a company, 

which resulted in a successful enforcement action that returned a signifcant amount 

of money to harmed investors. This was, at the time, the largest amount ever awarded 

to one individual under the SEC’s whistleblower program.21 On October 22, 2020, the 

Commission issued an award of over $114 million, which is the largest award in the 

program’s history, eclipsing the $50 million award made to the individual in June 2020. 

Almost $30 Million Awarded to Two Whistleblowers 

On September 30, 2020, the Commission announced an award of almost $30 million 

to two insider whistleblowers whose tips led SEC staff to open an investigation. The 

frst whistleblower, who was the frst 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 and 

received an award of approximately $7 million. The information and assistance 

provided by the whistleblowers helped the agency return tens of millions of dollars to 

harmed retail investors.22 

Over $27 Million Awarded to Whistleblower 

On April 3, 2020, the Commission announced an award of more than $27 million to a 

whistleblower who alerted the agency to misconduct occurring, in part, overseas. After 

providing the tip to the Commission, the whistleblower provided critical investigative 

leads that advanced the investigation and saved signifcant Commission resources.23 

Over $18 Million Awarded to Whistleblower 

On April 28, 2020, the Commission announced an award of more than $18 million to 

a whistleblower whose signifcant information prompted an examination that resulted 

in an important enforcement action. The whistleblower repeatedly reported the problem 

internally before contacting the SEC and suffered hardships as a result of the internal 

reporting. Because of this whistleblower’s actions, harmed investors were able to recover 

millions of dollars in losses.24 

21 See Order Determining Whistleblower Award Claim, Exchange Act Rel. No. 89002, File No. 2020-20 (June 4, 

2020); SEC Press Rel. No. 2020-126, “SEC Awards Record Payout of Nearly $50 Million to Whistleblower.” 

22 See Order Determining Whistleblower Award Claim, Exchange Act Rel. No. 90049, File No. 2020-36 (Sept. 

30, 2020); SEC Press Rel. No. 2020-239, “SEC Awards Almost $30 Million to Two Insider Whistleblowers.” 

23 See Order Determining Whistleblower Award Claim, Exchange Act Rel. No. 88658, File No. 2020-13 (Apr. 

16, 2020); SEC Press Rel. No. 2020-89, “SEC Awards Over $27 Million to Whistleblower.” 

24 See Order Determining Whistleblower Award Claims, Exchange Act Rel. No. 88759, File No. 2020-17 (Apr. 

28, 2020); SEC Press Rel. No. 2020-98, “SEC Awards Over $18 Million to Whistleblower.” 
WHISTLEBLOWER PROGRAM | 11 

More Than $10 Million Awarded to Whistleblower 

On September 14, 2020, the Commission announced an award of more than $10 

million to a whistleblower whose information and assistance were of crucial importance 

to a successful SEC enforcement action. The whistleblower made persistent efforts to 

expose serious fnancial misconduct and provided extensive and ongoing assistance to 

the investigative team over the course of the investigation. The whistleblower identifed 

witnesses and helped staff understand complex fact patterns and issues related to the 

matters under investigation.25 

More Than $7 Million Awarded to Whistleblower 

On February 28, 2020, the Commission announced an award of more than $7 million 

to a whistleblower whose information and assistance were critically important to 

the success of an enforcement action that focused on serious fnancial abuses. The 

whistleblower, while suffering hardships, showed great tenacity and effort in attempting 

to expose the misconduct that was the basis for the SEC’s action.26 

$5 Million Awarded to Whistleblower 

On April 20, 2020, the Commission announced a $5 million award to a whistleblower 

who provided signifcant information that led to a successful enforcement action. The 

whistleblower provided critical evidence of wrongdoing, which helped save time and 

resources in the SEC’s investigation. The whistleblower also suffered a unique hardship 

as a result of raising concerns internally.27 

$3.8 Million Awarded to Whistleblower 

On July 14, 2020, the Commission announced a $3.8 million award to a whistleblower 

who provided signifcant information that helped the SEC disrupt an ongoing 

fraudulent scheme. The resulting enforcement action returned millions of dollars to 

harmed investors.28 

Nearly $2.9 Million Awarded to Whistleblower 

On September 30, 2020, the Commission announced an award of nearly $2.9 million 

to a whistleblower who alerted the Commission to hard-to-detect violations. The 

whistleblower provided critical information and supporting evidence that conserved 

SEC time and resources.29 

25 See Order Determining Whistleblower Award Claim, Exchange Act Rel. No. 89850, File No. 2020-30 (Sept. 

14, 2020); SEC Press Rel. No. 2020-209, “SEC Awards More Than $10 Million to Whistleblower.” 

26 See Order Determining Whistleblower Award Claim, Exchange Act Rel. No. 88299, File No. 2020-7 (Feb. 

28, 2020); SEC Press Rel. No. 2020-46, “SEC Awards More Than $7 Million to Whistleblower.” 

27 See Order Determining Whistleblower Award Claim, Exchange Act Rel. No. 88689, File No. 2020-15 

(Apr. 20, 2020); SEC Press Rel. No. 2020-91, “SEC Issues $5 Million Whistleblower Award.” 

28 See Order Determining Whistleblower Award Claim, Exchange Act Rel. No. 89311, File No. 2020-23 

(July 14, 2020); SEC Press Rel. No. 2020-155, “SEC Issues $3.8 Million Whistleblower Award.” 

29 See Order Determining Whistleblower Award Claim, Exchange Act Rel. No. 90059, File No. 2020-39 

(Sept. 30, 2020); SEC Press Rel. No. 2020-240, “SEC Whistleblower Program Ends Record-Setting Fiscal 

Year with Four Additional Awards.” 
12 | U.S. SECURITIES AND EXCHANGE COMMISSION 

Over $2.5 Million Awarded to Joint Whistleblowers 

On September 1, 2020, the Commission announced an award of over $2.5 million to 

joint whistleblowers whose tip based largely on highly probative independent analysis 

of a public company’s flings led to several successful enforcement actions. In addition to 

their tip, the whistleblowers provided helpful assistance early in the investigation, which 

helped save the Commission time and resources.30 

$2.4 Million Awarded to Whistleblower 

On September 21, 2020, the Commission announced an award of $2.4 million to a 

whistleblower whose timely submission of information prompted the agency to initiate 

an investigation and bring an enforcement action that stopped ongoing misconduct, and 

whose assistance throughout the investigation contributed to all of the charges brought 

by the SEC. The whistleblower helped investigative staff target key information and 

identify important witnesses.31 

Approximately $2 Million Awarded to Whistleblower 

On April 3, 2020, the Commission announced an award of approximately $2 million 

to a whistleblower who provided vital information and assistance that substantially 

contributed to an ongoing investigation. The whistleblower’s information would have 

been diffcult for the agency to obtain absent the tip. The whistleblower expeditiously 

reported the information to the Commission and provided valuable assistance despite 

implied threats from the wrongdoers.32 

Almost $2 Million Awarded to Whistleblower 

On May 4, 2020, the Commission announced an award of nearly $2 million to a 

whistleblower whose information and assistance helped the agency bring a successful 

enforcement action and allowed investors to recover much of their money. The 

whistleblower’s information and assistance helped the SEC stop an ongoing fraud and 

aided the Commission’s ability to obtain an asset freeze and prevent the dissipation of 

investor funds.33 

Over $1.8 Million Awarded to Whistleblower 

On September 25, 2020, the Commission announced an award of over $1.8 million to 

a whistleblower who took both personal and professional risks in reporting information 

through the internal compliance system at a company. The tip revealed overseas conduct 

that would otherwise have been hard to detect. The whistleblower’s internal report 

resulted in an internal investigation at the company and a subsequent report of fnding 

to the SEC. The whistleblower also provided information to the SEC.34 

30 See Order Determining Whistleblower Award Claim, Exchange Act Rel. No. 89721, File No. 2020-28 

(Sept. 1, 2020); SEC Press Rel. No. 2020-201, “SEC Awards Over $2.5 Million to Joint Whistleblowers 

for Detailed Analysis That Led to Multiple Successful Actions.” 

31 See Order Determining Whistleblower Award Claim, Exchange Act Rel. No. 89929, File No. 2020-32 

(Sept. 17, 2020); SEC Press Rel. No. 2020-215, “SEC Issues $2.4 Million Whistleblower Award.” 

32 See Order Determining Whistleblower Award Claim, Exchange Act Rel. No. 88547, File No. 2020-12 

(Apr. 3, 2020); SEC Press Rel. No. 2020-80, “SEC Awards Approximately $2 Million to Whistleblower.” 

33 See Order Determining Whistleblower Award Claim, Exchange Act Rel. No. 88803, File No. 2020-18 

(May 4, 2020); SEC Press Rel. No. 2020-100, “SEC Awards Almost $2 Million to Whistleblower.” 

34 See Order Determining Whistleblower Award Claim, Exchange Act Rel. No. 89996, File No. 2020-34 

(Sept. 25, 2020); SEC Press Rel. No. 2020-225, “SEC Issues Two Whistleblower Awards for High-Quality 

Information Regarding Overseas Conduct.” 
WHISTLEBLOWER PROGRAM | 13 

Over $1.8 Million Awarded to Whistleblower 

On September 28, 2020, the Commission announced an award of over $1.8 million 

to a company outsider who expeditiously reported signifcant information to the 

Commission about ongoing securities law violations.35 

More Than $1.7 Million Awarded to Whistleblower 

On September 30, 2020, the Commission announced an award of more than $1.7 

million to a whistleblower who provided extensive and ongoing assistance to the 

investigative team over the course of the investigation.36 

Over $1.6 Million Awarded to Whistleblower 

On March 23, 2020, the Commission announced an award of more than $1.6 million 

to a whistleblower whose information tipped the agency to securities law violations and 

helped form part of the basis for charges brought in a successful enforcement action. 

Without the whistleblower’s information and assistance, the violations would have been 

diffcult to detect. In addition to the original tip, the whistleblower provided helpful 

assistance early in the investigation, preserving Commission time and resources.37 

Over $1.25 Million Awarded to Whistleblower 

On August 31, 2020, the Commission announced an award of over $1.25 million to 

a whistleblower whose signifcant information prompted the agency to initiate a cause 

examination and bring an enforcement action that resulted in the return of millions of 

dollars to harmed investors. The whistleblower’s vigilance and prompt reporting helped 

the agency move quickly to protect investors.38 

$750,000 Awarded to Whistleblower 

On September 25, 2020, the Commission announced an award of $750,000 to a 

whistleblower who reported securities violations occurring abroad to the SEC, which 

caused the SEC to open an investigation that resulted in a successful enforcement action. 

The whistleblower also reported the concerns internally.39 

Almost $700,000 Awarded to Whistleblower 

On June 19, 2020, the Commission announced an award of almost $700,000 to a 

whistleblower whose signifcant information helped the agency bring a successful 

enforcement action that resulted in the return of money to harmed investors. The 

whistleblower reported the problem internally before contacting the SEC in an effort to 

remedy the conduct.40 

35 See Order Determining Whistleblower Award Claim, Exchange Act Rel. No. 90021, File No. 2020-34 

(Sept. 28, 2020); SEC Press Rel. No. 2020-231, “SEC Issues $1.8 Million Whistleblower Award to a 

Company Outsider.” 

36 See Order Determining Whistleblower Award Claim, Exchange Act Rel. No. 90057, File No. 2020-38 

(Sept. 30, 2020); SEC Press Rel. No. 2020-240, “SEC Whistleblower Program Ends Record-Setting Fiscal 

Year with Four Additional Awards.” 

37 See Order Determining Whistleblower Award Claim, Exchange Act Rel. No. 88449, File No. 2020-8 (Mar. 

23, 2020); SEC Press Rel. No. 2020-69, “SEC Awards Over $1.6 Million to Whistleblower.” 

38 See Order Determining Whistleblower Award Claim, Exchange Act Rel. No. 89712, File No. 2020-27 

(Aug. 31, 2020); SEC Press Rel. No. 2020-199, “SEC Awards Over $1.25 Million to Whistleblower.” 

39 See Order Determining Whistleblower Award Claim, Exchange Act Rel. No. 89995, File No. 2020-33 

(Sept. 25, 2020); SEC Press Rel. No. 2020-225, “SEC Issues Two Whistleblower Awards for High-Quality 

Information Regarding Overseas Conduct.” 

40 See Order Determining Whistleblower Award Claim, Exchange Act Rel. No. 89102, File No. 2020-21 

(June 19, 2020); SEC Press Rel. No. 2020-138, “SEC Awards Almost $700,000 to Whistleblower.” 
14 | U.S. SECURITIES AND EXCHANGE COMMISSION 

Over $570,000 Awarded to Two Whistleblowers 

On March 24, 2020, the Commission announced awards totaling over $570,000 to 

two whistleblowers who provided signifcant information and assistance that helped the 

Commission bring multiple successful enforcement actions. The frst whistleblower, who 

reported early in the investigation and whose information related to all enforcement 

actions, received an award of approximately $478,000. The second whistleblower, 

whose information was important but only contributed to charges against one of the 

respondents, received an award of approximately $94,000.41 

$450,000 Awarded to Whistleblower 

On March 30, 2020, the Commission announced an award of $450,000 to a 

whistleblower whose signifcant information helped focus an ongoing investigation on 

the violations that were ultimately charged. The whistleblower, who had compliancerelated responsibilities, was eligible for an award because the whistleblower reported 

concerns about the relevant conduct internally within the company and then waited 120 

days before reporting to the SEC. This was the SEC’s third whistleblower award to an 

individual who had compliance or internal audit responsibilities.42 

Nearly $400,000 Awarded to Joint Whistleblowers 

On September 30, 2020, the Commission announced an award of nearly $400,000 to 

two whistleblowers who jointly provided a tip and gave continuing assistance during 

the course of the investigation. The whistleblowers met with staff and provided detailed 

information that helped the staff understand key documents and identify witnesses. The 

whistleblowers also reported their concerns and suffered personal hardships as a result 

of the reporting.43 

More than $277,000 Awarded to Whistleblower 

On January 22, 2020, the Commission announced an award of more than $277,000 to 

a whistleblower whose information alerted the agency to an ongoing fraudulent scheme 

that was preying on retail investors.44 

Over $260,000 Awarded to Joint Whistleblowers 

On November 15, 2019, the Commission announced a joint award of over $260,000 to 

three individuals who jointly submitted a tip alerting the agency to a well-concealed fraud 

operated by recidivist violators who targeted retail investors. The whistleblowers were 

harmed investors who provided information and assistance early in the investigation.45 

41 See Order Determining Whistleblower Award Claims, Exchange Act Rel. No. 88462, File No. 2020-9 

(Mar. 24, 2020); SEC Press Rel. No. 2020-71, “SEC Awards Over $570,000 to Two Whistleblowers.” 

42 See Order Determining Whistleblower Award Claim, Exchange Act Rel. No. 88507, File No. 2020-11 

(Mar. 30, 2020); SEC Press Rel. No. 2020-75, “SEC Awards Over $450,000 to Whistleblower.” 

43 See Order Determining Whistleblower Award Claim, Exchange Act Rel. No. 90054, File No. 2020-37 

(Sept. 30, 2020); SEC Press Rel. No. 2020-240, “SEC Whistleblower Program Ends Record-Setting Fiscal 

Year with Four Additional Awards.” 

44 See Order Determining Whistleblower Award Claim, Exchange Act Rel. No. 88015, File No. 2020-6 (Jan. 

22, 2020); SEC Press Rel. No. 2020-15, “SEC Awards Whistleblowers Whose Information Helped Stop 

Fraud.” 

45 See Order Determining Whistleblower Award Claims, Exchange Act Rel. No. 87544, File No. 2020-1 

(Nov. 15, 2019); SEC Press Rel. No. 2019-238, “SEC Awards Over $260,000 to Whistleblowers for Their 

Help in Spotting Securities Fraud.” 
WHISTLEBLOWER PROGRAM | 15 

Almost $250,000 Awarded to Joint Whistleblowers 

On September 17, 2020, the Commission announced an award of nearly $250,000 to 

joint whistleblowers. While the case was largely built through the investigative efforts 

of the staff, the tip caused the opening of an investigation that resulted in a successful 

enforcement action. The whistleblowers raised concerns internally before reporting the 

concerns to the Commission.46 

$125,000 Awarded to Whistleblower 

On June 23, 2020, the Commission announced an award of about $125,000 to a 

whistleblower whose information and assistance helped both the SEC and another 

agency bring successful actions against the perpetrator of a fraudulent securities offering 

that preyed on a vulnerable investor community.47 

More than $45,000 Awarded to Whistleblower 

On January 22, 2020, the Commission announced an award of more than $45,000 to 

a whistleblower who provided critical information that enabled the SEC staff to recover 

assets that were later returned to victims. The whistleblower was a harmed investor who 

lost money in the scheme.48 

Almost $30,000 Awarded to Whistleblower 

On September 8, 2020, the Commission announced a whistleblower award of almost 

$30,000 to a whistleblower whose information alerted the Commission to violations 

that would have been diffcult to detect in the absence of the information. In addition 

to the tip, the whistleblower provided exemplary assistance that saved the Commission 

resources and accelerated the pace of the investigation.49 

Award to Whistleblower 

On April 20, 2020, the Commission announced an award to a whistleblower who 

provided signifcant information that led to a successful enforcement action. The 

whistleblower reported the information internally, and in turn, submitted a written 

tip to the Commission. Enforcement staff opened the investigation after receiving the 

written tip and phone call with the whistleblower. The Commission brought an action 

based, in part, on the information provided by the whistleblower.50 

46 See Order Determining Whistleblower Award Claim, Exchange Act Rel. No. 89912, File No. 2020-31 

(Sept. 17, 2020); SEC Press Rel. No. 2020-214, “SEC Awards Almost $250,000 to Joint Whistleblowers.” 

47 See Order Determining Whistleblower Award Claims, Exchange Act Rel. No. 89124, File No. 2020-22 

(June 23, 2020); SEC Press Rel. No. 2020-141, “SEC Awards $125,000 to Whistleblower.” 

48 See Order Determining Whistleblower Award Claim, Exchange Act Rel. No. 88014, File No. 2020-5 (Jan. 22, 

2020); SEC Press Rel. No. 2020-15, “SEC Awards Whistleblowers Whose Information Helped Stop Fraud.” 

49 See Order Determining Whistleblower Award Claim, Exchange Act Rel. No. 89780, File No. 2020-29 

(Sept. 8, 2020). 

50 See Order Determining Whistleblower Award Claim, Exchange Act Rel. No. 88687, File No. 2020-16 

(Apr. 20, 2020). 
16 | U.S. SECURITIES AND EXCHANGE COMMISSION 

Award to Whistleblower 

On July 21, 2020, the Commission announced a 20% award to a whistleblower 

who expeditiously provided information concerning an ongoing fraud that prompted 

Enforcement staff to open an investigation. The claimant was unable to provide 

assistance beyond the initial tip. The claimant’s information resulted in the return of 

money to harmed investors.51 

Award to Whistleblower 

On July 21, 2020, the Commission announced a 30% award to a whistleblower who 

expeditiously provided information concerning an ongoing fraud that the Commission 

was not aware of at the time, and the whistleblower continued to provide ongoing 

assistance to staff in the investigation.52 

51 See Order Determining Whistleblower Award Claim, Exchange Act Rel. No. 89354, File No. 2020-25 

(July 21, 2020). 

52 See Order Determining Whistleblower Award Claim, Exchange Act Rel. No. 89355, File No. 2020-24 

(July 21, 2020). 
WHISTLEBLOWER PROGRAM | 17 

Rule 21F-6 Factors in Fiscal Year 2020 Awards 

In connection with the Whistleblower Rule amendments, to add transparency to the 

administration of the whistleblower program, the Commission directed OWB to include 

in its annual report to Congress, in aggregated form, an overview discussion of the 

factors that were present in the awards throughout the year, including a qualitative 

discussion of how the factors affected the Commission’s determination of the award 

amounts.53 In assessing the appropriate award amount, Exchange Act Rule 21F-6 

provides that the Commission consider: (1) the signifcance of information provided 

to the Commission; (2) the assistance provided in the Commission action; (3) law 

enforcement interest in deterring violations by granting awards; (4) participation in 

internal compliance systems; (5) culpability; (6) unreasonable reporting delay; and 

(7) interference with internal compliance and reporting systems.54 “

Approximately In FY 2020, the Commission issued whistleblower awards to 39 individuals in 

connection with 32 covered actions. Approximately two-thirds of the awards were at 

or near the statutory maximum award amount of 30%. two-thirds of the 

The signifcance of the whistleblower’s information was positively assessed by 

the Commission in more than 90% of the awards in FY 2020. In considering the awards were at or 

signifcance of the whistleblower’s information, the Commission looks at, among other 

things, whether the whistleblower’s information was the frst to alert Commission staff 

of the alleged misconduct, whether the violations would have been diffcult to detect near the statutory 

in the absence of the whistleblower’s information, and whether there is a close nexus 

between the whistleblower’s information and the resulting charges in the covered action. 

If the whistleblower’s information pertained, for example, only to part of the case, maximum award 

then it is more likely that the award amount was not materially increased based on the 

signifcance of the information factor. In one covered action where the Commission amount of 30%.” awarded less than 30%, the Commission observed that the “charges focused on 

violations occurring at a different subsidiary than the one identifed by Claimant in 

Claimant’s initial tip to the Commission, and . . . the case was largely built through 

information obtained from other sources.”55 In another covered action with an award 

of less than 30%, the Commission considered that the whistleblower’s information 

was “discrete and narrow in scope.”56 

The assistance factor also played a critical role in shaping the appropriate award 

amount for whistleblowers in FY 2020. In 72% of awards this year, the Commission 

positively assessed the level of the whistleblower’s assistance to the Commission staff. 

53 Adopting Release, Sept. 23, 2020, at 13. 

54 17 C.F.R. § 240.21F-6. 

55 Order Determining Whistleblower Award Claims, Exchange Act Rel. No. 89995, File No. 2020-33 (Sept. 

25, 2020). 

56 Order Determining Whistleblower Award Claims, Exchange Act Rel. No. 89311, File No. 2020-23 (July 

14, 2020). 
18 | U.S. SECURITIES AND EXCHANGE COMMISSION 

“Approximately 

81% of insiders 

who received 

awards in 

FY 2020 raised 

their concerns 

internally. . . .” 

As noted elsewhere in the report, under the Whistleblower Rule amendments, subject 

to certain exclusions, there is a presumption that a whistleblower’s award will be at 

the statutory maximum 30% if the award is $5 million or less. The presumption may 

be overcome where, for example, the whistleblower only provides limited assistance; 

however, OWB does not expect to recommend that the presumption be overcome in 

most circumstances. 

In all of the awards made in FY 2020, the existence of law enforcement interests was 

considered and positively assessed. When viewing the law enforcement interest factor, 

the Commission examines such things as whether money was returned to harmed 

investors,57 whether the alleged wrongdoing occurred abroad, and the amount of 

collections in the matter.58 To the extent any of these circumstances are present in a case, 

it is likely the award percentage will be increased because of the high law enforcement 

interests involved.59 

Internal reporting is the fnal positive factor that is considered in determining the 

appropriate award amount. While a whistleblower’s lack of internal reporting does 

not mean that the whistleblower will receive less than a maximum award, it can serve 

to increase an award amount. Approximately 81% of insiders who received awards 

in FY 2020 raised their concerns internally to their supervisors, compliance personnel, 

or through internal reporting mechanisms before reporting their information of 

wrongdoing to the Commission. Approximately 40% of the individuals who received 

awards this year were outsiders not affliated with the entity on which they were 

reporting, and certain of those outsiders also reported internally. When it occurred, 

internal reporting was positively assessed by the Commission. 

Rule 21F-6(b) provides that an award percentage may be reduced because of: (1) the 

culpability of the whistleblower; (2) unreasonable delay in reporting; or (3) interference 

with an internal compliance and reporting system. No award amounts were reduced in 

FY 2020 for culpability or interference with an internal reporting or compliance system. 

Only two awards were reduced this past fscal year for unreasonable reporting delay, 

and both involved delays that extended over multiple-year periods. On the other hand, 

the Commission determined not to reduce an award amount for unreasonable reporting 

delay where the whistleblower repeatedly and tenaciously raised concerns internally in 

an effort to remedy the misconduct.60 

57 See, e.g., Order Determining Whistleblower Award, Exchange Act Rel. No. 89002, File No. 2020-20 (June 

4, 2020). 

58 See, e.g., Order Determining Whistleblower Award, Exchange Act Rel. No. 89995, File No. 2020-33 (Sept. 

25, 2020). 

59 See, e.g., Order Determining Whistleblower Award, Exchange Act Rel. No. 88687, File No. 2020-16 (Apr. 

20, 2020). 

60 See Order Determining Whistleblower Award, Exchange Act Rel. No. 88658, File No. 2020-13 (Apr. 16, 

2020). 
WHISTLEBLOWER PROGRAM | 19 

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 

fling of the whistleblower tip to payment of the whistleblower award. As refected, 

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

receive payment of an award can be several years, particularly where the underlying 

investigation is especially complex, litigation is lengthy, there are multiple, competing 

award claims, or there are claims for related actions. OWB undertakes appropriate due 

diligence to ensure a careful and thorough evaluation of all award claims. 

HOW THE PROCESS WORKS 

Issued/Resolution Analysis Record and Determinations of Claims 

of Appeals Reconsideration Issued 

Requests 

$ 

Whistleblowers 

Investor 

Protection 

Fund 

Whistleblowers Tip Analysis/ Cases Filed/ Notices of Whistleblowers 

Submit Tips Investigation Penalties Covered Actions File Claims 

to the SEC Ordered Posted 

1 2 3 4 5

Final Orders Additional Possible Preliminary Review/Analysis 

10 9 8 7 6

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

(Step #4 above) to the issuance of a Final Order by the Commission (Step #10 above). 

NoCA Posted 

OWB posts on its webpage a NoCA for each Commission enforcement action where a 

fnal judgment or order, by itself or together with other judgments or orders in the same 

action, results in monetary sanctions exceeding $1 million.61 During FY 2020, OWB 

posted 105 NoCAs. 

OWB sends email alerts to GovDelivery62 when the NoCA listing is updated. 

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. 

61 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 fling an action 

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

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

Whistleblowers File Claims 

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

submitting a completed award application on Form WB-APP to OWB.63 Only claimants 

who have a clear nexus between the information they provided to the Commission and 

the charges in the underlying action should apply for an award in any given matter. 

In making that determination, claimants are encouraged to (i) consider whether they 

had any communications with the relevant Enforcement staff who brought the action 

and (ii) review the relevant charging documents and consider the proximity between 

the Commission’s specifc charges and the claimant’s information. The amendments to 

the Whistleblower Rules include tools intended to deter frivolous claims, which drain 

resources and slow down the review process for meritorious claims, including providing 

the Commission with the authority to permanently bar an individual from participation 

in the whistleblower program if he or she submits three or more award claims that the 

Commission fnds to be frivolous. Frivolous claims can substantially complicate and 

delay the award process. 

While OWB may contact whistleblowers who have worked with investigative staff to 

inform them of the application deadline, it is the responsibility of the claimant to make 

a timely application for award. The Commission has denied late-fled award claims. 

The Court of Appeals for the Second Circuit upheld the Commission’s denial of two 

claimants whose award applications were submitted approximately two years after 

the required deadline.64 As such, OWB encourages 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. 

Review and Analysis of Award Claims 

Based on an initial review of the award application and in consultation with 

investigative staff, OWB makes a preliminary assessment of the whistleblower claim. 

In keeping with OWB’s goal of processing meritorious claims, claims that appear 

to be eligible for an award are prioritized for processing. At the same time, during 

FY 2020, OWB dedicated two attorneys to reviewing likely non-meritorious claims, 

so that the majority of OWB attorneys may focus their time on processing likely 

meritorious award claims. 

OWB attorneys evaluate each application for a whistleblower award. In addition 

to analyzing the information provided by the claimant on the Form WB-APP, OWB 

attorneys may look at prior correspondence between the claimant and the Commission 

and may consult intra-agency databases to understand the origin of the case and what 

tips or other correspondence the claimant may have submitted to the Commission. 

In addition, OWB attorneys work closely with investigative staff responsible for 

the relevant action, and/or other Commission staff who may have interacted with 

the claimant or have other relevant knowledge, to understand the contribution or 

involvement the claimant may have had in the matter. 

63 17 C.F.R. §§ 240. 21F-10(a), (b). 

64 See Order Determining Whistleblower Award Claim, Exchange Act Release No. 77368 (Mar. 14, 2016), 

pet. for rev. denied sub nom. Cerny v. SEC, 707 F. App’x 29 (2d Cir. 2017), cert. denied, 138 S. Ct. 2005 

(2018); see also LaViola v. SEC, No. 19-1079, 2019 WL 3229356 (D.C. Cir. July 16, 2019) (unpublished). 
WHISTLEBLOWER PROGRAM | 21 

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

application, as well as other relevant materials reviewed, OWB attorneys prepare a 

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

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

Depending on the complexity of the claim, the number of claimants who applied, 

and whether OWB is awaiting input from others, including from other agencies in 

connection with related action claims, this due diligence process may take a signifcant 

amount of time. Generally, all recommendations go through a multi-tiered, robust 

review process. Certain claims, including all award recommendations, are also 

reviewed by Enforcement’s Offce of Chief Counsel and the Commission’s Offce 

of the General Counsel. 

Preliminary Determinations Issued 

The Claims Review Staff, designated by the Director of Enforcement, considers 

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

forth in Dodd-Frank and the Whistleblower Rules. The Claims Review Staff currently 

is composed of seven senior offcers in Enforcement, including the Director and 

Deputy Director of Enforcement. The Claims Review Staff then issues a Preliminary 

Determination setting forth its assessment of whether the claim should be approved 

or denied and, if approved, setting forth the proposed award amount.65 Beginning on 

the effective date of the Whistleblower Rule amendments, OWB expects to follow a 

summary disposition process for certain categories of denials of award applications 

that are relatively straightforward. Under this process, OWB, rather than the CRS, 

would assume responsibility for reviewing the record, and then issue a Preliminary 

Summary Disposition identifying the basis for the denial of the application for award. 

We anticipate that using the summary disposition process will help increase effciencies 

in the claims review process. 

For awards, 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 amount.66 Award amounts are based on the particular facts and circumstances of 

each case. 

Factors that may increase an award amount include the signifcance 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 an entity’s internal reporting channels or mechanisms.67 

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

culpable or involved in the underlying misconduct, including whether the whistleblower 

fnancially benefted from the misconduct, interfered with internal compliance systems, 

or unreasonably delayed in reporting the violation to the Commission. 

65 17 C.F.R. § 240.21F-10(d). 

66 Id. § 240.21F-6. 

67 But see the discussion of the Digital Realty decision on page 26 of this report. 
22 | U.S. SECURITIES AND EXCHANGE COMMISSION 

Possible Record and Reconsideration Requests 

A claimant 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 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 confdentiality agreement limiting the use of such materials to 

the claims review process.68 In keeping with our statutory obligation of confdentiality, 

OWB carefully redacts each record to remove any information that could identify 

another whistleblower in the matter. A claimant also has 30 calendar days from the date 

of the Preliminary Determination 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.69 If a claim is denied and the claimant 

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 through operation of law. 

Requests for reconsideration should include new information or arguments and not 

simply restate what was included in the original award claim application. Requests 

for reconsideration should be submitted in one written response. OWB attorneys 

may spend a considerable amount of time evaluating requests for reconsideration. 

OWB attorneys analyze claimants’ legal arguments and take other steps before 

recommending a Proposed Final Determination for the Claims Review Staff to submit 

to the Commission. Because of the amount of time it takes to process reconsideration 

requests, OWB encourages claimants and their counsel to consider the merits of their 

reconsideration request in a particular matter and not to ask for reconsideration as a 

matter of course. 

Final Order Issued and Resolution of Appeals 

After considering any requests for reconsideration, the Claims Review Staff makes 

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

its decision.70 

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 claimant objected 

to the Preliminary Determination.71 

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

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

[Preliminary Determination] materials.” 

69 17 C.F.R. § 240.21F-10(e). 

70 Id. §§ 240.21F-10(g)-(h). 

71 Id. §§ 240.21F-10(f), (h). 
WHISTLEBLOWER PROGRAM | 23 

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

request that the Proposed Final Determination be further 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.72 

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 claimants’ 

confdentiality. 

There are several factors that may affect the length of time it takes for OWB to review 

an award claim and for the Commission to issue a Final Order. For example, the 

number of claimants, both meritorious and non-meritorious, applying for an award 

in connection with a Covered Action affects the time it takes to process a claim. 

Similarly, the presence of novel or complex issues, or the need to supplement the record 

with additional information from the claimant, may also lengthen the time it takes to 

process a claim. There may be a delay when there is a claim for an award in connection 

with a related action, requiring OWB to coordinate with or receive assistance from 

another regulator to understand what contribution the whistleblower may have made 

in the related action. Additionally, requests for the record and for reconsideration can 

substantially delay the issuance of a Final Order. 

72 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). 
24 | U.S. SECURITIES AND EXCHANGE COMMISSION 

“Protecting 

whistleblower 

confdentiality is an 

integral component 

of the whistleblower 

program.” 

PROFILES OF AWARD RECIPIENTS 

Protecting whistleblower confdentiality is an integral component of the whistleblower 

program. Dodd-Frank 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, as well as the award percentage. 

Consistent with our statutory obligation to maintain whistleblower confdentiality but 

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

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

end of FY 2020—while still protecting the identity of any particular individual. 

Since program inception, the Commission has issued awards of approximately 

$562 million to 106 individuals in connection with 87 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 specifc. For example, the 

whistleblowers identifed particular individuals involved in the misconduct, or provided 

specifc documents that substantiated their allegations or explained where such 

documents could be located. In some instances, the whistleblowers identifed specifc 

fnancial transactions that evidenced fraud, or provided detailed assessment of the 

wrongdoing. The misconduct reported by award recipients is often relatively current 

or ongoing at the time it was reported to the Commission. Additionally, nearly all 

of the 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 his or her information leads to 

a successful enforcement action—meaning generally that the original information either 

caused the staff to open an examination or investigation, or the original information 

signifcantly contributed to a successful enforcement action where the matter was 

already under examination or investigation. Of the whistleblowers who have received 

awards under the program, approximately 71% provided original information that 

caused staff to open an investigation or examination, and approximately 29% received 

awards because their original information signifcantly contributed to an alreadyexisting investigation or examination. In assessing whether information assisted with 

an ongoing matter, the Commission considers factors such as whether the information 

allowed the Commission to bring an action in signifcantly less time or with fewer 

resources, and whether it supported additional successful charges, or successful claims 

against additional individuals or entities.73 When the Commission has found claimants 

to be ineligible for awards on non-procedural grounds, it is often because the claimants’ 

information did not result in the opening of an investigation or examination or opening 

of a new line of inquiry in an existing investigation or examination, or signifcantly 

contribute to an ongoing investigation or examination. 

73 Securities Whistleblower Incentives and Protections, 76 Fed. Reg. 34,300, 34,325 (June 13, 2011). 
WHISTLEBLOWER PROGRAM | 25 

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

employee or company insider to be eligible for an award. However, approximately 

68% 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 those recipients, 

approximately 84% 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. 

Award recipients have also included investors who had been victims of the fraud, 

professionals working in the same or related industry, or other types of outsiders, such 

as individuals who had a personal relationship with the wrongdoer or individuals who 

have a special expertise in the market. 

Whistleblowers have helped the Commission bring cases against a variety of individuals 

and entities, many of which are involved in the fnancial services industry. Individuals 

comprised approximately 45% of the defendants and respondents in cases resulting 

in whistleblower awards. Approximately 33% of the defendants and respondents in 

cases in which a whistleblower received an award concerned entities registered with the 

Commission, including broker-dealers, investment advisers, or other registered market 

participants. Unregistered entities comprised approximately 22% of the defendants and 

respondents. 

In addition, whistleblowers have assisted the Commission in bringing enforcement 

cases involving an array of securities violations, including offering frauds, such as 

Ponzi schemes, false or misleading statements in a company’s offering memoranda or 

marketing materials, false pricing information, accounting violations, internal controls 

violations, Foreign Corrupt Practices Act violations, and insider trading, among other 

types of misconduct. 

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

tip to the Commission. Twelve of the matters for which whistleblower awards 

were ordered involved two or more whistleblowers jointly submitting information 

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. Ten award 

recipients to date 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 19 recipients were foreign nationals or residents of foreign countries at the 

time they submitted their tips to the Commission. 
26 | U.S. SECURITIES AND EXCHANGE COMMISSION 

“To date, 

the Commission 

has brought 

12 enforcement 

actions or 

administrative 

proceedings involving 

violations of 

Rule 21F-17.” 

PRESERVING INDIVIDUALS’ RIGHTS TO 

REPORT TO THE COMMISSION AND SHIELDING 

EMPLOYEES FROM RETALIATION 

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

broadened prohibitions against retaliation.74 Following the passage of Dodd-Frank, 

the Commission implemented rules that enabled the SEC to take legal action against 

employers who have retaliated against whistleblowers. To date, the Commission has 

brought three anti-retaliation enforcement actions. 

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 confdentiality 

agreement . . . with respect to such communications.”75 To date, the Commission has 

brought 12 enforcement actions or administrative proceedings involving violations of 

Rule 21F-17. In the most recent action, Collector’s Coffee,76 the Commission included 

a Rule 21F-17 charge against the defendants for impeding the efforts of harmed 

investors to report misconduct to the Commission. According to the allegations in the 

amended complaint, after the investors sued the defendants, defendants entered into 

a settlement agreement with the investors that expressly prohibited the investors from 

speaking to the Commission about their claims. The amended complaint further alleges 

the defendants went so far as to sue two investors that they believed breached one of 

the settlement agreements. The Commission’s enforcement action remains pending in 

federal court in New York. 

In February 2018, the Court in Digital Realty held that the whistleblower provisions of 

the Exchange Act require that an employee report a possible securities law violation to 

the Commission to qualify for protection against employment retaliation under Section 

21F. The Court thus invalidated the Commission’s rule interpreting Section 21F’s antiretaliation protections to apply in cases where an employee had reported only internally. 

The rule amendments modify Rule 21F-2 to comport with the Court’s holding by, 

among other things, establishing a uniform defnition of “whistleblower” that would 

apply to all aspects of Exchange Act Section 21F. 

Retaliation protection remains a key tenet of the whistleblower program. OWB 

continues to support enforcement investigations involving (1) whistleblowers who 

suffered retaliation after reporting securities violations to the Commission and 

(2) whistleblowers who were impeded from communicating directly with staff in 

violation of Rule 21F-17(a). For example, OWB continues to work with investigative 

staff to identify and investigate practices in the use of confdentiality and other kinds of 

agreements that interfere with individuals’ abilities to report potential wrongdoing to 

the Commission. 

74 15 U.S.C. § 78u-6(h)(1). 

75 17 C.F.R. § 240.21F-17(a). 

76 U.S. Sec. & Exch. Comm’n v. Collector’s Coffee, Inc. (d/b/a Collectors Café) & Mykalai Kontilai, No. 

19-cv-04355-LGS-GWG (S.D.N.Y.) (Nov. 4, 2019). 
WHISTLEBLOWER PROGRAM | 27 

WHISTLEBLOWER TIPS RECEIVED 

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.77 The Whistleblower Rule 

amendments, as discussed below, allow individuals to submit their Form TCR within 

30 days of providing their original information to the Commission or of frst obtaining 

actual or constructive notice of the requirements. Whistleblowers who use the online 

portal to submit a tip receive a computer-generated confrmation of receipt with a TCR 

submission number. All whistleblower tips referring to potential securities law violations 

are entered into the TCR System and are evaluated by the Commission’s Offce of 

Market Intelligence (OMI) within Enforcement. The Commission’s TCR System was 

updated in FY 2018 to include more user-friendly features, including the ability to 

upload larger attachments. OWB encourages individuals and their counsel to submit 

tips using the Commission’s online portal, rather than through a hard-copy Form 

TCR. Due to the increasing volume of mailed and faxed submissions, and the ready 

availability of electronic submissions, OWB no longer provides acknowledgement letters 

in response to paper flings. Claimants and their counsel are encouraged to submit their 

tip via only one method. For example, the same tip should not be entered through the 

online portal and then mailed in hard-copy to the offce. This can create duplication of 

work for intake staff. 

Number of Whistleblower Tips 

In FY 2020, the Commission received over 6,900 whistleblower tips—the largest 

number of whistleblower tips received in a fscal year, which represents a 31 percent 

increase over FY 2018 for which the Commission received the second highest number 

of whistleblower tips in a fscal year. Since August 2011, the Commission has received 

over 40,200 whistleblower tips. The table below shows the number of whistleblower 

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

whistleblower program.78 

“In FY 2020, 

the Commission 

received over 6,900 

whistleblower tips— 

the largest number of 

whistleblower 

tips received in a 

fscal year.” 

FY2020 

FY2019 

FY2018 

FY2017 

FY2016 

FY2015 

FY2014 

FY2013 

FY2012 

5,212 

5,282 

4,484 

4,218 

3,923 

3,620 

3,238 

3,001 

6,911 

1000 2000 3000 4000 5000 6000 7000 

77 17 C.F.R. § 240.21F-9(a). 

78 The Commission also receives tips from individuals who do not wish to be part of the whistleblower 

program. The data in this report is limited to whistleblower tips and does not refect all tips or complaints 

received by the Commission during the fscal year. 

0 
28 | U.S. SECURITIES AND EXCHANGE COMMISSION 

From FY 2012, the frst year for which we have full-year data,79 to FY 2020, the 

number of whistleblower tips received by the Commission has grown by approximately 

130 percent. 

Whistleblower Allegation Type 

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

should identify the nature of their complaint allegations. In FY 2020, the most common 

complaint categories reported by whistleblowers were Corporate Disclosures and 

Financials (25 percent), Offering Fraud (16 percent), and Manipulation (14 percent).80 

The following graph refects the number of whistleblower tips received in FY 2020 by 

allegation type.81 

Corporate Offering Manipulation Insider Initial Coin FCPA Unregistered Market Municipal 

Disclosures Fraud Trading Offerings and Offerings Event Securities and 

and Financials Cryptocurrencies Public Pension 

369 

1,078 

942 

345 

300 

Trading and 

Pricing 

208 

137 

96 

37 

500 

1000 

1500 

2000 

1,710 

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

data is available for FY 2011. 

80 This breakdown refects the categories selected by whistleblowers and, thus, the data represents the 

whistleblower’s own characterization of the violation type. 

81 In addition, there were approximately 1,689 whistleblower tips where the submitter identifed the 

whistleblower TCR as not ftting into any allegation category that is listed on the questionnaire or did not 

provide an allegation category. 

0 
WHISTLEBLOWER PROGRAM | 29 

The types of securities violations reported by whistleblowers have remained generally 

consistent. 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 2017 through FY 2020. 

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 2020, California, Pennsylvania, New York, Florida, and Texas yielded the 

highest number of whistleblower tips domestically. 

FREQUENCY

0–20

21–40

41–60

61–100

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

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

whistleblower tips from individuals in approximately 130 countries outside the United 

States. In FY 2020 alone, the Commission received whistleblower submissions from 

individuals in 78 foreign countries. After the United States, OWB received the highest 

number of whistleblower tips this past fscal year from individuals in Canada, the 

United Kingdom, and the People’s Republic of China. The map below refects the 

countries in which whistleblower tips originated during FY 2020. 

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 2020. 
WHISTLEBLOWER PROGRAM | 31 

PROCESSING OF WHISTLEBLOWER TIPS 

Intake of Hard-Copy Form TCRs 

Prior to July 2020, OWB staff provided for the intake of hard-copy tips on Form TCRs 

and uploaded them to the Commission’s TCR System. In order to allow OWB staff to 

focus more on the processing of award claims, in July, the responsibilities associated 

with the intake of hard-copy tips were moved to OMI. Not only did this allow OWB 

to focus more time and resources on the processing of award claims, it also created 

greater effciencies in the triaging of tips, as OMI reviews and evaluates all tips, whether 

submitted in hard-copy or through the on-line portal. 

We strongly encourage whistleblowers to submit any TCRs and additional 

information using the SEC’s online portal, particularly given the full-time mandatory 

telework posture due to COVID-19. Any TCRs or additional information submitted 

by mail should be sent to the SEC’s alternative mailing address, which is posted on the 

SEC whistleblower program webpage, until further notice. 

TCR Evaluation 

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

references a possible securities law violation. OMI 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 beneft from the specifc 

expertise of another Division or Offce within the SEC, the tip is forwarded to staff in 

that Division or Offce for further analysis. When OMI determines that a tip should 

be considered for investigation, OMI assigns the tip to one of the Commission’s eleven 

regional offces, a specialty unit, or to an Enforcement group in the Home Offce. Tips 

that relate to an existing investigation are forwarded to the staff working on the matter. 

The Commission may use information from whistleblower tips 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 signifcantly contributes to an ongoing or already-existing 

investigation. Tips may also prompt the Commission to commence an examination of a 

regulated entity, which may lead to an enforcement action. 

OWB tracks whistleblower tips that are referred to Enforcement staff for investigation. 

OWB currently is tracking over 1,100 matters in which a whistleblower’s tip has caused 

a Matter Under Inquiry or investigation to open, or has been forwarded to Enforcement 

staff for review and consideration in connection with an ongoing investigation. Not all 

of these matters, however, will result in an enforcement action, or an enforcement action 

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

Whistleblower tips may also be used to open an examination or referred to examination 

staff in connection with a planned or ongoing exam. 
32 | U.S. SECURITIES AND EXCHANGE COMMISSION 

In general, whistleblower tips that are specifc, credible, and timely, and that are 

accompanied by corroborating documentary evidence, are more likely to be forwarded 

to investigative staff for further analysis or investigation. For instance, if the tip 

identifes 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 are less likely to be forwarded 

to or investigated by Enforcement staff. 

In certain instances, OMI or other Enforcement staff may determine it is more 

appropriate that a whistleblower’s tip be investigated by another regulatory or law 

enforcement agency. When this occurs, the tip is referred to the other agency in 

accordance with the Exchange Act’s whistleblower confdentiality requirements. 

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

group usually are forwarded to the Commission’s Offce of Investor Education and 

Advocacy (OIEA) for resolution. Comments or questions about agency practice or the 

federal securities laws also are forwarded to OIEA. 
WHISTLEBLOWER PROGRAM | 33 

AMENDMENTS TO WHISTLEBLOWER RULES 

On September 23, 2020, the Commission voted to adopt amendments to the 

Whistleblower Rules designed to provide greater clarity to whistleblowers and increase 

the program’s effciency and transparency. The amendments will become effective on 

December 7, 2020. The rule amendments increase effciencies around the review and 

processing of whistleblower award claims, and provide the Commission with additional 

tools to appropriately reward meritorious whistleblowers for their efforts 

and contributions to a successful matter. 

Additional Tools in Award Determinations 

• Presumption of the statutory maximum award amount for certain awards of 

$5 million and less: Historically, approximately 75% of the awards issued in the 

whistleblower program have been $5 million or less. 

∘ For awards where the statutory maximum award amount for the covered 

action and any related actions is in the aggregate $5 million or less, newly 

added Exchange Act Rule 21F-6(c) provides a presumption that the 

Commission will pay a meritorious claimant the statutory maximum amount 

where none of the negative award criteria specifed in Rule 21F-6(b) are 

present, subject to certain limited exceptions. 

∘ For awards over $5 million, the Commission will continue to analyze 

the award factors identifed in Rule 21F-6 and issue awards based on the 

application of those factors. Based on the historical application of the award 

factors, if none of the negative criteria specifed in Rule 21F-6(b) are present, 

the award amount would be expected to be in the top third of the award range. 

∘ After carefully considering the comments received, the Commission determined 

not to adopt proposed Exchange Act Rule 21F-6(d)(2), which would have 

provided a formalized process for the Commission to conduct an enhanced 

review of certain awards. 

• Allowing awards based on deferred prosecution agreements (DPAs) and nonprosecution agreements (NPAs) entered into by the U.S. Department of Justice 

(DOJ), or a settlement agreement entered into by the Commission outside of 

the context of a judicial or administrative proceeding to address violations of 

the securities laws: This amendment will ensure that whistleblowers are not 

disadvantaged because of the particular form of an action that the Commission or 

DOJ may elect to pursue. Under the amendment, the Commission has the ability 

to make award payments to whistleblowers based on money collected as a result 

of such DPAs and NPAs, as well as under settlement agreements entered into by 

the Commission outside of the context of a judicial or administrative proceeding to 

address violations of the securities laws. 
34 | U.S. SECURITIES AND EXCHANGE COMMISSION 

∘ The amendment to the defnition of “action” to include NPAs, DPAs, and 

similar Commission settlement agreements will apply to any such agreement 

that was entered into after July 21, 2010 (the date Dodd-Frank became 

effective). Individuals will have 90 days from the effective date of the 

amendments to apply for an award in connection with any such agreement 

that was entered between the July 2010 date and the effective date of the 

amendments. 

• Clarifying the current defnition of “related action”: This amendment codifes 

the Commission’s approach to determining whether an action is a related action, 

including clarifying that a law-enforcement or separate regulatory action does not 

qualify as a “related action” if the Commission determines that there is a separate 

award scheme that more appropriately applies to such law-enforcement or separate 

regulatory action. The presence of such a separate award scheme would not affect 

the Commission’s determination of the award based on the monetary sanctions 

collected by the Commission in the covered SEC action and any related action 

where such an award scheme was not present. 

Uniform Definition of “Whistleblower” 

In response to the Supreme Court’s decision in Digital Realty, the Commission modifed 

Rule 21F-2 to establish a uniform defnition of “whistleblower” that will apply to 

all aspects of Exchange Act Section 21F—i.e., the award program, the heightened 

confdentiality requirements, and the employment anti-retaliation protections. 

• For purposes of retaliation protection, an individual is required to report 

information about possible securities laws violations to the Commission “in 

writing.” As required by the Supreme Court’s decision, to qualify for the retaliation 

protection under Section 21F, the individual must report to the Commission before 

experiencing the retaliation. 

• To be eligible for an award or to obtain heightened confdentiality protection, the 

additional existing requirement that a whistleblower submit information on Form 

TCR or through the Commission’s online tips portal remains in place, subject to the 

additional discretion of the Commission to grant waivers described below. 

• Additionally, the Commission is issuing interpretive guidance defning the scope 

of retaliatory conduct prohibited by Section 21F(h)(1)(A), which includes any 

retaliatory activity by an employer against a whistleblower that a reasonable 

employee would fnd materially adverse. 
WHISTLEBLOWER PROGRAM | 35 

Increased Efficiency in Claims Review Process 

The new presumption for certain awards of $5 million or less, described above, should 

result in gains in effciency from streamlining the award determination process for 

those awards. Two further amendments are designed to help increase the Commission’s 

effciency in processing whistleblower award applications. 

• New subparagraph (e) to Exchange Act Rule 21F-8 codifes the Commission’s 

practice of barring applicants who include materially false, fctitious, or fraudulent 

statements in their whistleblower submission, in their other dealings with the 

Commission, or in related actions, and provides an important new tool for the 

Commission in processing frivolous award applications. 

∘ To prevent repeat submitters from abusing the award application process, the 

rule permits the Commission to permanently bar any applicant from seeking 

an award after the Commission determines that the applicant has abused the 

process by submitting three frivolous award applications. 

∘ For the frst three applications determined to be frivolous, OWB will notify a 

claimant of its assessment and give the claimant the opportunity to withdraw 

the application. 

• New Exchange Act Rule 21F-18 affords the Commission with a summary 

disposition procedure for certain types of common denials, such as untimely 

award applications, applications that involve a tip that was not provided to the 

Commission in the form and manner that the rules require, and applications where 

the claimant’s information was never provided to or used by staff responsible for 

the investigation. 

∘ The more streamlined process is designed to help facilitate a more timely 

resolution of such relatively straightforward denials, while freeing up staff 

resources to focus on processing potentially meritorious award claims. 

Claimants will still have an opportunity to contest a preliminary denial of 

their claim before the Commission makes its fnal determination. 
36 | U.S. SECURITIES AND EXCHANGE COMMISSION 

Clarification and Enhancement of Certain Policies and Procedures 

The rule amendments also clarify and enhance certain policies, practices, and procedures 

in implementing the program. These amendments include the items listed below. 

• Exchange Act Rule 21F-4(e) was amended to clarify the defnition of “monetary 

sanctions,” consistent with the Commission’s existing practice. 

• Section 21F of the Exchange Act provides that the determination of the amount 

of an award is in the discretion of the Commission. Exchange Act Rule 21F-6 was 

amended to clarify the Commission’s discretion in applying the award factors and 

setting the award amount, including the discretion to apply the award factors in 

percentage terms, dollar terms, or some combination thereof. The amendments also 

confrm that the Commission will consider only the enumerated award factors set 

forth in the rule when determining the award amount. 

• Exchange Act Rule 21F-9 was amended to provide the Commission with additional 

fexibility to modify the manner in which individuals may submit Form TCR. 

∘ Further, the amendment clarifes that the Commission may waive compliance 

with Rule 21F-9(a) and (b) for a meritorious whistleblower who provided a 

Form TCR: 

• within 30 days of frst providing the information that he or she relies upon 

as a basis for a claim, or 

• within 30 days of frst obtaining actual or constructive notice about those 

requirements (or 30 days from the date the whistleblower retains counsel 

to represent him or her in connection with the submission of original 

information, whichever occurs frst). 

∘ The waiver of non-compliance with Rule 21F-9(a) and (b) is automatic, rather 

than discretionary, when the Commission fnds that the whistleblower has 

established that the specifed conditions are satisfed. 

∘ The Commission continues to retain its separate discretionary exemptive 

authorities under Rule 21F-8(a) and Exchange Act Section 36(a) for 

circumstances that may warrant exemptive relief. 

• Exchange Act Rule 21F-8 was amended to provide the Commission with additional 

fexibility regarding the forms used in connection with the whistleblower program. 

• Exchange Act Rule 21F-12 was amended to clarify the list of materials that the 

Commission may rely upon in making an award determination. 

• Exchange Act Rule 21F-13 was amended to clarify the materials that may comprise 

the administrative record for purposes of judicial review. 
WHISTLEBLOWER PROGRAM | 37 

Commission Interpretive Guidance 

In addition to the foregoing rule amendments, the Commission published interpretive 

guidance to help clarify the meaning of “independent analysis” as that term is defned in 

Exchange Act Rule 21F-4 and utilized in award applications. 

• Under the guidance, in order to qualify as “independent analysis,” a whistleblower’s 

submission must provide evaluation, assessment, or insight beyond what would be 

reasonably apparent to the Commission from publicly available information. 

• In making that determination, the Commission will consider whether the 

whistleblower’s conclusion of possible securities violations derives from multiple 

sources, including sources that are not readily identifed and accessed by a member 

of the public without specialized knowledge, unusual effort, or substantial cost, and 

the sources collectively raise a strong inference of a potential securities law violation 

that is not readily inferable by the Commission from any of the sources individually. 

Finally, the Commission did not adopt a specifc time-based presumption of 

“unreasonable delay” as interpretive guidance. The Commission will continue to assess 

the facts and circumstances of each case to determine whether any delay was reasonably 

attributable to actions taken by or circumstances out of the control of the whistleblower 

or to unreasonable actions by the whistleblower. 

Guidance from the Office of the Whistleblower 

To increase clarity and transparency in the award determination process, OWB issued 

staff guidance regarding the process for determining award amounts for eligible 

whistleblowers, contemporaneously with the adoption of the rule amendments. The 

guidance refects OWB’s experience with the program as well as the implementation of 

the rule amendments, and it sets forth the process for OWB to propose award amounts 

to the Claims Review Staff. This guidance is publicly available on the OWB’s web page 

at https://www.sec.gov/fles/owb-award-determination-guidance2.pdf. 

Additional Information to Congress 

The Commission also directed OWB to include in its annual reports to Congress 

(beginning with this FY 2020 report), in an aggregated manner, an overview discussion 

of the factors that were present in the awards throughout the year, including (to 

the extent practicable) a qualitative discussion of how these factors affected the 

Commission’s determination of award amounts. Pages 17 to 18 of this report address 

this requirement. 
38 | U.S. SECURITIES AND EXCHANGE COMMISSION 

SECURITIES AND EXCHANGE COMMISSION

INVESTOR PROTECTION FUND 

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

for the Commission’s whistleblower award program, including the payment of awards 

in related actions.82 As required by statute, all payments are made out of this Fund, 

which is fnanced 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 fnance the operations of the suggestion 

program of the SEC’s Offce of Inspector General.83 The suggestion program is intended 

for the receipt of suggestions from SEC employees for improvements in work effciency, 

effectiveness, productivity, and the use of resources at the Commission, as well as 

allegations by SEC employees of waste, abuse, misconduct, or mismanagement within 

the Commission, and is operated outside of OWB.84 

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

83 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 Offce 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). 

84 Section 4D(a) of the Exchange Act, id. § 78d-4(a). 
WHISTLEBLOWER PROGRAM | 39 

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 2020. 

FY 2020 

Balance of Fund at beginning of fscal year $ 403,975,928.95 

Reversal of prior year sequestered amount85 $ 10,112,385.86 

Amounts deposited into or credited to Fund during fscal year $ 17,057,314.18 

Amounts of interest receipts from investments during fscal year $ 4,960,413.69 

Current year sequestered amount85 $ (1,299,045.94) 

Amounts paid from Fund during fscal year to whistleblowers $ (95,733,263.56) 

Amounts estimated to be paid from Fund during fscal year $ (95,317,161.45) 

to whistleblowers 

Reversal of obligations accrued in prior years $ 16,538,714.03 

Amount disbursed to Offce of the Inspector General $ (13,731.50) 

during fscal year 

Balance of Fund at end of fscal year $ 260,281,554.26 

Whenever the balance of the Fund falls below $300 million, a statutory replenishment 

mechanism is triggered. For a complete description of the mechanisms that Congress 

established to replenish the Fund, see Section 21F(g)(3) of the Exchange Act, 

15 U.S.C. 78-6(g)(3). 

Section 21F(g)(5) of the Exchange Act also requires the Commission to provide a 

complete set of audited fnancial statements for the Fund, including a balance sheet, 

income sheet, income statement, and cash-fow analysis. That information will be 

included in the Commission’s Agency Financial Report, which will be separately 

submitted to Congress. 

85 Amounts relate to available resources temporarily reduced during the fscal year as a result of the Budget 

Control Act of 2011 through the process known as “sequestration.” These amounts become available at 

the beginning of the following fscal year. 
40 | U.S. SECURITIES AND EXCHANGE COMMISSION 

APPENDIX A 

WHISTLEBLOWER TIPS BY ALLEGATION TYPE 

COMPARISON OF FISCAL YEARS 2017-2020 

2,000 

1,500 

1,000 

500 

0 

1,710 

2020 

2017 

2018 

2019 

1,107 

1,078 

1,054 

983 

954 942 

758 

692 

624 

535 

468 

369 

345 333 

300 289 271 262 252 

231 222 210 201 202 200208

157 144 138 137 125 

96 

67 57 48 35 37 

Corporate Offering Manipulation Insider Initial Coin Trading and FCPA Unregistered Market Municipal 

Disclosures Fraud Trading Offerings and Pricing Offerings Event Securities and 

and Financials Cryptocurrencies Public Pension 

*The “Crypto Currency” allegation category was introduced during the fourth quarter of FY 2018. In addition to what is depicted in the graph, there were 

several whistleblower tips where the submitter identifed the WB TCR as not ftting into any allegation category that is listed on the questionnaire or did not 

provide an allegation category. 
WHISTLEBLOWER PROGRAM | 41 

APPENDIX B 

WHISTLEBLOWER TIPS RECEIVED BY GEOGRAPHIC LOCATION 

UNITED STATES AND ITS TERRITORIES, FISCAL YEAR 2020* 

AK 

AL 

AR 

AZ 

CA 

CO 

CT 

DC 

DE 

FL 

GA 

GU 

HI 

IA 

ID 

IL 

IN 

KS 

KY 

LA 

MA 

MD 

ME 

MI 

MN 

MO 

MP 

MS 

MT 

NC 

ND 

NE 

NH 

NJ 

NM 

NV 

NY 

OH 

OK 

OR 

PA 

PR 

RI 

SC 

SD 

TN 

TX 

UT 

VA 

VT 

WA 

WI 

WV 

WY 

3 

30 

10 

103 

731 

86 

33 

17 

10 

277 

87 

1 

17 

16 

14 

158 

34 

29 

28 

25 

70 

61 

12 

66 

48 

43 

1 

6 

5 

82 

11 

14 

10 

156 

11 

60 

320 

81 

33 

37 

643 

7 

8 

39 

5 

50 

247 

35 

71 

6 

94 

38 

5 

3 

0 100 200 300 400 500 600 

*Approximately 4,087 WB TCRs were submitted in the United States or a U.S. territory during FY 2020, which constitutes approximately 59 percent 

of the WB TCRs submitted during this period. In addition, approximately 2,073 WB TCRs, constituting approximately 30 percent of the WB TCRs 

submitted in FY 2020, were submitted with an unknown foreign or domestic geographical categorization or were submitted anonymously through 

counsel. 

700 
42 | U.S. SECURITIES AND EXCHANGE COMMISSION 

APPENDIX C 

WHISTLEBLOWER TIPS RECEIVED BY GEOGRAPHIC LOCATION 

INTERNATIONAL, FISCAL YEAR 2020* 

ARGENTINA 

AUSTRALIA 

AUSTRIA 

BELARUS 

BELGIUM 

BERMUDA 

BOSNIA AND HERZEGOVINA 

BOTSWANA 

BRAZIL 

CANADA 

CHILE 

CHINA, PEOPLE’S REPUBLIC OF 

COLOMBIA 

COSTA RICA 

CROATIA 

CUBA 

CURAÇAO 

CYPRUS 

CZECH REPUBLIC 

DEMOCRATIC REPUBLIC OF CONGO 

DENMARK 

DOMINICAN REPUBLIC 

ESTONIA 

ETHIOPIA 

FINLAND 

FRANCE 

GERMANY 

GREECE 

HONG KONG 

HUNGARY 

ICELAND 

INDIA 

INDONESIA 

IRAN 

IRELAND 

ISRAEL 

ITALY 

JAPAN 

KAZAKHSTAN 

KENYA 

KUWAIT 

MALAYSIA 

MEXICO 

MONACO 

MONGOLIA 

MONTENEGRO 

NEPAL 

NETHERLANDS 

NEW ZEALAND 

NICARAGUA 

NIGERIA 

NORWAY 

PAKISTAN 

PERU 

PHILIPPINES 

POLAND 

PORTUGAL 

ROMANIA 

RUSSIA 

SAUDI ARABIA 

SINGAPORE 

SLOVAK REPUBLIC 

SOUTH AFRICA 

SOUTH KOREA 

SPAIN 

SURINAME 

SWEDEN 

SWITZERLAND 

TAIWAN 

THAILAND 

TURKEY 

UGANDA 

UKRAINE 

UNITED ARAB EMIRATES 

UNITED KINGDOM 

UZBEKISTAN 

VENEZUELA 

ZIMBABWE 

0 

84 

15 

15 

32 

43 

10 20 30 40 50 60 70 80 90 100 

2 

29 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

6 

2 

2 

2 

2 

2 

2 

2 

3 

3 

3 

3 

4 

4 

4 

4 

23 

91 

67 

48 

25 

9 

14 

6 

6 

6 

6 

13 

12 

3 

3 

3 

8 

18 

4 

10 

25 

14 

8 

8 

7 

5 

3 

11 

* Approximately 751 WB TCRs were submitted from abroad during FY 2020, which constitutes approximately 11 percent of the WB TCRs submitted during 

this period. 

OFFICE OF THE WHISTLEBLOWER 

Washington, DC