Whistleblower 

Program

2019 ANNUAL REPORT TO CONGRESS

U.S. SECURITIES AND EXCHANGE COMMISSION
DISCLAIMER

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

and Exchange Commission. The Commission 

has expressed no view regarding the analysis, 

findings, or conclusions contained herein.

DISCLAIMER

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

and Exchange Commission. The Commission 

has expressed no view regarding the analysis, 

findings, or conclusions contained herein.

DISCLAIMER

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

and Exchange Commission. The Commission 

has expressed no view regarding the analysis, 

findings, or conclusions contained herein.

DISCLAIMER

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

and Exchange Commission. The Commission 

has expressed no view regarding the analysis, 

findings, or conclusions contained herein.
Report available on the Web at: www.sec.gov/whistleblower

CONTENTS

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

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

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

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

Whistleblower Awards Made in Fiscal Year 2019. . . . . . . . . . . . . . . . . 9

Overview of Award Process. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

Profiles of Award Recipients. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

Preserving Individuals’ Rights to Report to the Commission and 

Shielding Employees from Retaliation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

Whistleblower Tips Received. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

Number of Whistleblower Tips. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

Whistleblower Allegation Type. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

Geographic Origin of Whistleblower Tips. . . . . . . . . . . . . . . . . . . . . . 24

Processing of Whistleblower Tips. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

TCR Evaluation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

Assistance by OWB. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

Securities and Exchange Commission Investor Protection Fund. . . . . . . . . . . 28

Appendix A. Whistleblower Tips by Allegation Type

Comparison of Fiscal Years 2016–2019. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

Appendix B. Whistleblower Tips Received by 

Geographic Location, United States and Its Territories, Fiscal Year 2019. . . .32

Appendix C. Whistleblower Tips Received by 

Geographic Location International, Fiscal Year 2019. . . . . . . . . . . . . . . . . . . 33

WHISTLEBLOWER PROGRAM | 1

“The SEC has 

ordered wrongdoers 

in enforcement 

matters brought 

with information 

from meritorious 

whistleblowers to pay 

over $2 billion in total 

monetary sanctions.”

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

OFFICE OF THE WHISTLEBLOWER

The U.S. Securities and Exchange Commission’s (SEC or Commission) 

whistleblower program continued to have a significant impact on the Commission’s 

enforcement and investor protection efforts in Fiscal Year (FY) 2019. In addition 

to multiple awards being granted for information impacting retail investors, the 

program has also reached a momentous milestone. Since the program’s inception, 

the SEC has ordered wrongdoers in enforcement matters brought with information 

from meritorious whistleblowers to pay over $2 billion in total monetary sanctions, 

including more than $1 billion in disgorgement of ill-gotten gains and interest, of which 

almost $500 million has been, or is scheduled to be, returned to harmed investors. 

We continue to take pride in the whistleblower program’s contributions to the 

protection of markets and investors including, importantly, Main Street investors.

In FY 2019, the Commission received its second largest number of whistleblower tips 

in a fiscal year and made its third largest award to date—a $37 million award to a 

whistleblower who provided significant evidence and assistance that enabled the agency 

to bring the matter to an efficient and successful resolution. This award followed a 

$50 million award to joint claimants in March 2018 and a $39 million award to a 

whistleblower in September 2018. While all awards are important to the Commission 

and to whistleblowers, these larger awards reflect the significance of the information 

that whistleblowers are providing to the Commission and are testaments to the 

whistleblower program’s success.

Whistleblower Awards Made in Fiscal Year 2019

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

approximately $387 million to 67 individuals. Despite an unusual year challenged by 

a lapse in appropriations, in FY 2019, the SEC awarded approximately $60 million in 

whistleblower awards to eight individuals whose information and cooperation assisted 

the Commission in bringing successful enforcement actions. 

Information from whistleblowers in FY 2019 helped the Commission bring a variety of 

enforcement actions, including actions involving wrongdoing against retail investors and 

difficult-to-detect misconduct occurring abroad. Recipients of whistleblower awards 

in FY 2019 were diverse, including overseas whistleblowers and insiders who reported 

internally and took meaningful and timely steps in an effort to have their employer 

remediate the harm caused by the misconduct. Three award recipients in FY 2019 

were located abroad, or reported conduct that was occurring abroad, demonstrating the 

international reach of the program. Three award recipients reported misconduct that 

was impacting retail investors, furthering a Commission priority to protect the Main 
2 | U.S. SECURITIES AND EXCHANGE COMMISSION

Street investor. Seven of the eight award recipients reported their concerns to the 

company. We hope that the awards made in FY 2019 will continue to incentivize 

individuals, both in the U.S. and abroad, to report high-quality information regarding 

potential securities laws violations promptly to the Commission, which in turn, helps 

the Commission better protect investors and the marketplace.

Whistleblower Tips Received and Communications in Fiscal Year 2019

The Commission received over 5,200 whistleblower tips in FY 2019, the second 

highest number of tips received in a fiscal year and a 74 percent increase since the 

beginning of the program. 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 70 countries outside of the United States, as well as 

from every state in the United States. The tips covered a broad range of allegation 

types, including nearly 300 tips relating to cryptocurrencies, an emerging area of 

interest in FY 2019.

The Office of the Whistleblower (the Office or 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 2019, 

OWB staff returned over 2,600 calls to the public. Since the hotline was established, 

the Office has returned nearly 24,000 calls responding to questions about the program. 

Retaliation and Agreements to Impede

The Office continues to work with the SEC’s Division of Enforcement (Enforcement) 

staff to review fact patterns of potential retaliation and attempts to impede 

communications with the Commission. Whistleblower protections continue to be 

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

safe reporting to the SEC without fear of reprisal.

Whistleblower Rule Amendments

In FY 2019, the Commission continued to consider the public comments received on 

the Whistleblower Rule amendments proposed in June 2018. In addition to clarifying 

the requirements for anti-retaliation protections under the whistleblower statute 

following the Supreme Court’s ruling in Digital Realty Trust, Inc. v. Somers1 (Digital 

Realty), the proposed amendments would, among other things, provide tools to 

increase efficiencies in the claims review process and address other topics that have 

developed during the program’s eight year history. We anticipate new rules being 

adopted in FY 2020. 

1 138 S. Ct. 767 (2018).

“The Commission 

received over 5,200 

whistleblower tips 

in FY 2019, the second 

highest number of 

tips received in a 

fiscal year and a 

74 percent increase 

since the beginning of 

the program”
WHISTLEBLOWER PROGRAM | 3

“The whistleblower 

program continues to 

have a significant positive 

impact on the Commission’s 

enforcement efforts and 

protection of investors and 

markets, including assisting 

the Commission . . . 

in the return of hundreds 

of millions of dollars to 

harmed investors, many 

being Main Street 

investors, as a result of 

whistleblower tips.”

Conclusion

The whistleblower program continues to have a significant positive impact on the 

Commission’s enforcement efforts and protection of investors and markets, including 

assisting the Commission with actions that resulted in the return of hundreds of millions 

of dollars to harmed investors, many being Main Street investors, as a result of whistleblower tips. We look forward to the continuing growth and success of the program and 

the anticipated increased efficiencies in claims processing that the rule amendments will 

provide in the upcoming fiscal years. 

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, Office of the Whistleblower

November 15, 2019
4 | U.S. SECURITIES AND EXCHANGE COMMISSION

HISTORY AND PURPOSE

The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank)2

amended the Securities Exchange Act of 1934 (Exchange Act)3 by, among other things, 

adopting Section 21F,4 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.5

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

of the monetary sanctions collected.6 To ensure that whistleblower payments would 

not diminish the amount of recovery for victims of securities law violations, Congress 

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

eligible whistleblowers are paid. 

The Commission established OWB, an office within Enforcement, to administer and 

effectuate the whistleblower program. It is OWB’s mission to administer a vigorous 

whistleblower program that will help the Commission identify and halt securities frauds 

early and quickly to minimize investor losses. 

In addition to establishing an awards program to encourage the submission of highquality information, Dodd-Frank and the Commission’s Whistleblower Rules7

 also 

establish confidentiality protections for whistleblower submissions,8 including the 

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

Employers are prohibited from retaliating against whistleblowers for providing 

information to the Commission.9

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

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

the following subjects:

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

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

preceding fiscal year;

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

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

3 15 U.S.C. § 78a, et seq.

4 Id. § 78u-6.

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

6 15 U.S.C. § 78u-6(b)(1).

7 17 C.F.R. §§ 240.21F-1 through 21F-17. 

8 Id. § 240.21F-7.

9 15 U.S.C. § 78u-6(h)(1). The Commission proposed rule amendments to 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.

10 15 U.S.C. § 78u-7(d).

“Employers are 

prohibited from 

retaliating against 

whistleblowers 

for providing 

information to 

the Commission.”
WHISTLEBLOWER PROGRAM | 5

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

fiscal year;

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

the preceding fiscal year;

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

whistleblowers pursuant to Section 21F(b);

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

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

income statement, and cash flow analysis.11

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

report, which covers the period October 1, 2018 through September 30, 2019, 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 2019, 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 2019 primarily address the requirements of Section 21F(g)(5) of the Exchange Act. 

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

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

WHISTLEBLOWER

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

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

Exchange Act. Jane Norberg heads the Office as Chief of OWB. There are currently 

two Assistant Directors and nine attorneys who are dedicated to the work of the 

Office, which includes, among other things, processing award claims, as well as two 

attorneys devoted to communications with the public. OWB’s work is also furthered 

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

and an administrative assistant. Following is an overview of OWB’s primary responsibilities and activities over the past fiscal year. 

Assessment of Award Applications 

The whistleblower program was designed, in part, to provide 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 webpage12 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 significantly 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 confirm they are aware of the posting and applicable 

deadline for submitting claims for award. 

Based on an initial review, as well as communications with the relevant investigative 

staff, OWB prioritizes those claims that appear to be award-eligible. At the same time, 

OWB may process non-meritorious or frivolous claims that are easy to process in an 

effort to gain efficiencies and conserve resources. 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. OWB then makes recommendations to 

the Claims Review Staff, currently comprised of five senior officers in Enforcement, 

as to award eligibility. Pages 9-16 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 fiscal year.

12 www.sec.gov/whistleblower/claim-award

“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.”
WHISTLEBLOWER PROGRAM | 7

Advancing Anti-Retaliation Protections and Combating 

Efforts to Impede Reporting

OWB identifies and monitors whistleblower complaints alleging retaliation by 

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

securities law violations. 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, 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 confidentiality, 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 confidentiality agreement 

. . . with respect to such communications.”13 OWB continues to work with investigative 

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

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

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.14 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. In 

FY 2019, OWB benefited from the updated version of the TCR System that the 

Commission implemented in FY 2018. OWB encourages all individuals to submit 

their whistleblower tips and any additional information electronically through the 

Commission’s online portal. There are several advantages to using the online portal, 

including the fact that individuals receive an immediate acknowledgement of their 

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

in a queue for staff who triage tips and complaints. For greater efficiency and quicker 

review, OWB recommends electronic submission over hard-copy submission.

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

pages 22-25 of this report.

13 17 C.F.R. § 240.21F-17(a).

14 17 C.F.R. § 240.21F-9(a).

“OWB encourages 

all individuals to 

submit their 

whistleblower tips 

and any additional 

information 

electronically through 

the Commission’s 

online portal.”
8 | U.S. SECURITIES AND EXCHANGE COMMISSION

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 2019, the Office returned over 2,600 phone calls from members of the 

public. Since the hotline was established, OWB has returned nearly 24,000 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 confidentiality of a 

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

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

agency to handle the caller’s tip. OWB 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 Office 

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 Office aims to promote 

the program and educate the public about the program through OWB’s webpage.15

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. In FY 2019, 

OWB published information on its approach to processing whistleblower award 

claims on its webpage.16

OWB also actively participates in numerous webinars, media interviews, 

presentations, press releases, and other public communications. In FY 2019, OWB 

participated in many public engagements aimed at promoting and educating the public 

about the Commission’s whistleblower program. The Office’s target audience generally 

includes potential whistleblowers, whistleblower counsel, and corporate compliance 

counsel and professionals. OWB’s Chief also participates in legal panels and forums 

with other federal agencies with similar whistleblower programs. 

15 www.sec.gov/whistleblower

16 www.sec.gov/files/OWB%20Approach%20to%20Processing%20Award%20Claims.pdf

“Since the hotline 

was established, 

OWB has returned 

nearly 24,000 calls 

from the public.”
WHISTLEBLOWER PROGRAM | 9

CLAIMS FOR AWARDS

Whistleblower Awards Made in Fiscal Year 2019

In FY 2019, the Commission ordered whistleblower awards of approximately 

$60 million to eight individuals, each of whom voluntarily provided original 

information that either led to the opening of an investigation or significantly 

contributed to a successful enforcement action.

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

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 2019.

The awards highlighted in red were ordered this past fiscal year.

$50 million $37 million

$50 million

$39 million

$17 million

$14 million

$15 million

$33 million

$30 million

$22 million

$20 million

Per Award Amount

March 2018

September 2018

March 2019

March 2018

September 2014

August 2016

November 2016

June 2016

September 2018

September 2013

From program inception to end of Fiscal Year 2019, the SEC awarded approximately $387 million to 67 individuals.

$83 million

$54 million

$16 million

$14 million

$7 million

$30 million

$22 million

$20 million

$17 million

Per Covered Action

March 2018

September 2018

March 2019

September 2014

August 2016

November 2016

June 2016

November 2017

September 2013

January 2017

TOP 10 SEC WHISTLEBLOWER AWARDS
10 | U.S. SECURITIES AND EXCHANGE COMMISSION

Below is an overview of the whistleblower awards made by the Commission during the 

past fiscal year.

$50 Million Awarded to Two Whistleblowers

On March 26, 2019, the Commission announced awards totaling $50 million to 

two whistleblowers whose high-quality information assisted the agency in bringing a 

successful enforcement action. One individual received an award of $37 million, and 

the other received an award of $13 million. The $37 million award is the Commission’s 

third largest award to date, after the $50 million award made in March 2018 to joint 

whistleblowers and the more than $39 million award in September 2018. Both 

whistleblowers provided information that prompted Commission staff to open the 

investigations and thereafter met with Commission staff. The whistleblower who 

received the $37 million award met with investigative staff multiple times and 

provided information and documentation that was of significantly high quality and 

critically important to the staff’s ability to bring the investigations to an efficient and 

successful resolution.17

$4.5 Million Awarded to Whistleblower Whose Internal Reporting 

Led to Successful SEC Case and Related Action

On May 24, 2019, the Commission announced an award of more than $4.5 million 

to a whistleblower whose tip triggered the company to review the allegations as part 

of an internal investigation and subsequently report the whistleblower’s allegations to 

the SEC and another agency. As a result of the self-report by the company, the SEC 

opened its own investigation into the alleged misconduct. This was the first time a 

whistleblower was awarded under the provision of the Whistleblower Rules that was 

designed to incentivize internal reporting by whistleblowers who also report the same 

information to the Commission within 120 days. Although Commission staff never 

communicated with the whistleblower or the whistleblower’s counsel, the whistleblower 

was credited for the company’s internal investigation because the allegations were 

reported to the Commission within 120 days of the report to the company. The 

Commission found that the Claimant also contributed to the success of the related 

action and awarded the claimant the same percentage for both actions.18

$3 Million Awarded to Joint Whistleblowers

On June 3, 2019, the Commission announced an award of $3 million to joint 

whistleblowers whose tip launched the SEC’s investigation and subsequent successful 

enforcement action involving an alleged securities law violation that impacted retail 

customers. In reaching the award determination, the Commission positively assessed 

the significant and timely steps the claimants undertook in an effort to have the firm 

remediate the harm caused by the alleged violations, including advocating for full 

disclosure of the violation and for compensation of harmed investors. In addition to 

17 See Order Determining Whistleblower Award Claims, Exchange Act Rel. No. 85412, File No. 2019-4 

(March 26, 2019); SEC Press Rel. No. 2019-42, “SEC Awards $50 Million to Two Whistleblowers.” 

18 See Order Determining Whistleblower Award Claims, Exchange Act Rel. No. 85936, File No. 2019-6 

(May 24, 2019); SEC Press Rel. No. 2019-76, “SEC Awards $4.5 Million to Whistleblower Whose Internal 

Reporting Led to Successful SEC Case and Related Action.”
WHISTLEBLOWER PROGRAM | 11

participating in the firm’s internal compliance system promptly after learning of 

the misconduct, claimants assisted the staff by meeting with them in person and 

identifying potential witnesses and also experienced hardships by raising concerns 

about the violation.19

More Than $1.8 Million Awarded to Whistleblower

On August 29, 2019, the Commission announced an award of more than $1.8 million 

to a whistleblower who provided critical information and assistance to Commission 

staff. After alerting the Commission to the misconduct, which occurred overseas, 

the whistleblower provided extensive and ongoing cooperation during the course of 

the investigation, including identifying witnesses, assisting with testimony preparation, 

and encouraging witnesses to cooperate with Enforcement staff. The whistleblower 

in this matter also internally reported the conduct on multiple occasions. The 

whistleblower’s information and assistance resulted in a programmatically significant 

enforcement action.20

SEC Awards Half-Million Dollars to Overseas Whistleblower

On July 23, 2019, the Commission announced a $500,000 award to an overseas 

whistleblower whose expeditious reporting helped the Commission bring a successful 

enforcement action involving misconduct occurring abroad. The whistleblower’s tip was 

the first information that the Commission received on the charged misconduct.21

More Than $38,000 Awarded to Whistleblower

On September 20, 2019, the Commission issued a Final Order for an award of more 

than $38,000 to a whistleblower whose quick reporting prompted Enforcement staff 

to open an investigation that resulted in the filing of two successful enforcement actions 

involving harm to retail investors. The whistleblower provided investigative testimony 

and encouraged others to cooperate with Commission staff.22

19 See Order Determining Whistleblower Award Claims, Exchange Act Rel. No. 86010, File No. 2019-7 

(June 3, 2019); SEC Press Rel. No. 2019-81, “SEC Awards $3 Million to Joint Whistleblowers.”

20 See Order Determining Whistleblower Award Claim, Exchange Act. Rel. No. 86803, File No. 2019-9 

(Aug. 29, 2019); SEC Press Rel. No. 2019-165, “SEC Awards More Than $1.8 Million to Whistleblower.”

21 See Order Determining Whistleblower Award Claims, Exchange Act Rel. No. 86431, File No. 2019-8 

(July 23, 2019); SEC Press Rel. No. 2019-138, “SEC Awards Half-Million Dollars to Overseas 

Whistleblower.”

22 See Order Determining Whistleblower Award Claim, Exchange Act. Rel. No. 87039, File No. 2019-11 

(Sept. 20, 2019).
12 | U.S. SECURITIES AND EXCHANGE COMMISSION

Overview of Award Process 

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

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

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

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

receive 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.

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 

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

action results in monetary sanctions exceeding $1 million.23 During FY 2019, OWB 

posted 151 NoCAs.

OWB sends email alerts to GovDelivery24 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.

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

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

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

24 GovDelivery is a vendor that provides communications for public-sector clients.

$

Whistleblowers

Investor 

Protection 

Fund

Whistleblowers

Submit Tips 

to the SEC

Tip Analysis/

Investigation

Cases Filed/

Penalties 

Ordered

Notices of 

Covered Actions 

Posted

Whistleblowers 

File Claims

1 2 3 4 5

Final Orders 

Issued/Resolution 

of Appeals

Additional 

Analysis

Possible 

Record and 

Reconsideration 

Requests

Preliminary 

Determinations 

Issued

Review/Analysis 

of Claims

10 9 8 7 6

HOW THE PROCESS WORKS
WHISTLEBLOWER PROGRAM | 13

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.25 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 specific charges and the claimant’s 

tip. The proposed amendments to the Whistleblower Rules include tools intended to 

deter frivolous claims, which drain resources and slow down the review process for 

meritorious claims. 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-filed 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.26 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, OWB may 

process non-meritorious or frivolous claims that are easy to process in an effort to 

gain efficiencies and conserve resources. 

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 may 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.

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. 

25 17 C.F.R. §§ 240. 21F-10(a), (b).

26 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).
14 | U.S. SECURITIES AND EXCHANGE COMMISSION

Depending on the complexity of the award 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 significant 

amount of time.

Generally, most non-frivolous award claim recommendations also go through a 

multi-tiered, robust review process, including review and comment by Enforcement’s 

Office of Chief Counsel and the Commission’s Office of the General Counsel. 

Preliminary Determinations Issued

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

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

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

currently is composed of five senior officers in Enforcement, including the Co-Directors 

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.27

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.28 Award amounts are based on the particular facts and circumstances of 

each case. 

Factors that may increase an award amount include the significance of the information 

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

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

violation internally through an entity’s internal reporting channels or mechanisms.29

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

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

financially benefited from the misconduct, interfered with internal compliance systems, 

or unreasonably delayed in reporting the violation to the 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 confidentiality agreement limiting the use of such 

materials to the claims review process.30 In keeping with our statutory obligation of 

confidentiality, OWB carefully redacts each record to remove any information that 

could identify another whistleblower in the matter. A claimant also has 30 calendar 

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

27 17 C.F.R. § 240.21F-10(d).

28 Id. § 240.21F-6.

29 But see the discussion of the Digital Realty decision on page 21 of this report. 

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

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

[Preliminary Determination] materials.”

“Award amounts 

are based on 

the particular facts 

and circumstances 

of each case.”
WHISTLEBLOWER PROGRAM | 15

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.31 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.

Requests for reconsideration should include new information or argument and not 

simply restate what was included in the original award claim application. 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. OWB welcomes meritorious 

reconsideration requests.

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.32

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.33

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.34

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’ confidentiality. 

31 17 C.F.R. § 240.21F-10(e).

32 Id. §§ 240.21F-10(g)-(h).

33 Id. §§ 240.21F-10(f), (h).

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

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

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

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. 
WHISTLEBLOWER PROGRAM | 17

PROFILES OF AWARD RECIPIENTS

Protecting whistleblower confidentiality 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. 

Consistent with our statutory obligation to maintain whistleblower confidentiality but 

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

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

end of FY 2019—while still protecting the identity of any particular individual. 

Since program inception, the Commission has issued awards of approximately 

$387 million to 67 individuals in connection with 55 Covered Actions, as well as 

in connection with several related actions. Many of the tips or complaints that 

were submitted by these successful whistleblowers share similar characteristics. 

The information provided by each award recipient was specific. For example, the 

whistleblowers identified particular individuals involved in the misconduct, or 

provided specific documents that substantiated their allegations or explained where 

such documents could be located. In some instances, the whistleblowers identified 

specific financial 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 significantly 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 

68 percent provided original information that caused staff to open an investigation 

or examination, and approximately 32 percent received awards because their 

original information significantly contributed to an already-existing investigation or 

examination. In assessing whether information assisted with an ongoing matter, 

the Commission considers factors such as whether the information allowed the 

“Since program 

inception, the 

Commission has issued 

awards of approximately 

$387 million to 67 

individuals in connection 

with 55 Covered 

Actions, as well as in 

connection with several 

related actions.”
18 | U.S. SECURITIES AND EXCHANGE COMMISSION

Commission to bring an action in significantly less time or with fewer resources, 

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

additional individuals or entities.35 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, opening 

of a new line of inquiry in an existing investigation or examination, nor significantly 

contributed to an ongoing investigation or examination. 

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 

69 percent of the award recipients to date were current or former insiders of the 

entity about which they reported information of wrongdoing to the SEC. Of those 

recipients, approximately 85 percent raised their concerns internally to their supervisors, 

compliance personnel, or through internal reporting mechanisms, or understood that 

their supervisor or relevant compliance personnel knew of the violations, before 

reporting their information of wrongdoing to the Commission.

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 financial services industry. Individuals 

comprised approximately 40 percent of the defendants and respondents in cases 

resulting in whistleblower awards. Approximately 33 percent 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 

26 percent 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 or Ponzi-like schemes, false or misleading statements in a company’s offering 

memoranda or marketing materials, false pricing information, accounting violations, 

internal controls violations, and Foreign Corrupt Practices Act (FCPA) violations, 

among other types of misconduct. 

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

to the Commission. Eight of the matters for which whistleblower awards were 

ordered involved two or more whistleblowers jointly submitting information to 

the Commission. 

35 Securities Whistleblower Incentives and Protections, 76 Fed. Reg. 34,300, 34,325 (June 13, 2011).

“Past whistleblower 

award recipients hail 

from several different 

parts of the United 

States, and fifteen 

recipients were foreign 

nationals or residents 

of foreign countries 

at the time they 

submitted their tips to 

the Commission.”
WHISTLEBLOWER PROGRAM | 19

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. Seven of the 

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 fifteen recipients were foreign nationals or residents of foreign countries at 

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

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

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

E M P LOY E E S F R O M R E TA L I AT I O N 

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

broadened prohibitions against retaliation.36 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 confidentiality 

agreement . . . with respect to such communications.”37 To date, the Commission 

36 15 U.S.C. § 78u-6(h)(1).

37 17 C.F.R. § 240.21F-17(a).
WHISTLEBLOWER PROGRAM | 21

“Retaliation 

protection remains 

a key tenet of the 

whistleblower 

program.”

has brought eleven enforcement actions or administrative proceedings involving 

violations of Rule 21F-17. One of the most recent actions, Securities and Exchange 

Commission v. Kenneth W. Crumbley, Jr. and Sedona Oil & Gas Corp., Civil Action 

No. 3:16-CV-00172 (N.D. Tex.), settled at the end of FY 2018. The action involved 

the fraudulent offer and sale of oil and gas investments. The Commission alleged that 

the defendants engaged in the deliberate destruction of evidence in the months leading 

up to the action and that defendant Crumbley threatened to terminate Sedona 

employees for speaking with Commission staff or other government authorities. 

As part of the settlement, the Court ordered that Crumbley be enjoined from future 

violations of Rule 21F-17.

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 anti-retaliation protections to apply in cases where an employee had reported 

only internally. The proposed rule amendments will modify Rule 21F-2 to comport 

with the Court’s holding by, among other things, establishing a uniform definition 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 where retaliation occurred after the 

whistleblower reported securities violations to the Commission and continues to 

support the enforcement of the whistleblower protections of Exchange Act Rule 

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

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

engagement in other practices, to interfere with individuals’ abilities to report 

potential wrongdoing to the Commission.
22 | U.S. SECURITIES AND EXCHANGE COMMISSION

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

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

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

by mailing or faxing their tips on Form TCR to OWB.38 Whistleblowers who use the 

online portal to submit a tip receive a computer-generated confirmation 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 

Office 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 filings. 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 office. This can create 

duplication of work for intake staff. 

Number of Whistleblower Tips

In FY 2019, the Commission received more than 5,200 tips—the second largest number 

of tips received in a fiscal year, just slightly below the number of tips received in FY 

2018. Since August 2011, the Commission has received over 33,300 whistleblower tips. 

The table below shows the number of whistleblower tips received by the Commission 

on a yearly basis.39

From FY 2012, the first year for which we have full-year data,40 to FY 2019, the 

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

74 percent. 

38 17 C.F.R. § 240.21F-9(a).

39 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 reflect all tips or complaints 

received by the Commission during the fiscal year. 

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

data is available for FY 2011. 

0 1000 2000 3000 4000 5000 6000

FY2019 5,212

FY2018

FY2017

FY2016

FY2015

FY2014

FY2013

FY2012

5,282

4,484

4,218

3,923

3,620

3,238

3,001
WHISTLEBLOWER PROGRAM | 23

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 2019, the most common 

complaint categories reported by whistleblowers were Corporate Disclosures and 

Financials (21 percent), Offering Fraud (13 percent), and Manipulation (10 percent).41

The following graph reflects the number of whistleblower tips received in FY 2019 by 

allegation type.42

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

whistleblower’s own characterization of the violation type. 

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

any allegation category that is listed on the questionnaire. 

0

500

1000

1500

2000

200

FCPA

289

Crypto 

Currency

1,107

Corporate 

Disclosures 

and Financials

131

Not Reported

535

Manipulation

222

Insider

Trading

201

Trading and

Pricing

48

Market

Event

35

Municipal

Securities and 

Public Pension

1,614

Oering Other

Fraud

692

Unregistered

Oerings

138
24 | U.S. SECURITIES AND EXCHANGE COMMISSION

The types of securities violations reported by whistleblowers have remained generally 

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

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

as the three highest allegation types reported by whistleblowers. Crypto Currency 

was added to the TCR System as an allegation type in the fourth quarter of FY 2018. 

The Commission received nearly 300 tips (6 percent), the fourth highest allegation 

type, relating to cryptocurrencies in FY 2019. Appendix A to this report provides a 

comparison among the number of whistleblower tips by allegation type that the 

Commission received during FY 2016 through FY 2019. 

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 2019, California, Pennsylvania, New York, Texas, and Florida yielded the 

highest number of whistleblower tips domestically.

FREQUENCY

0–20

21–40

41–60

61–100

>101
WHISTLEBLOWER PROGRAM | 25

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

whistleblower tips from individuals in 123 countries outside the United States. In FY 

2019 alone, the Commission received whistleblower submissions from individuals in 

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

whistleblower tips this past fiscal year from individuals in Canada, Germany, and the 

United Kingdom. The map below reflects the countries in which whistleblower tips 

originated during FY 2019.

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 2019. 
26 | U.S. SECURITIES AND EXCHANGE COMMISSION

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

OMI evaluates incoming whistleblower TCRs and assigns specific, credible, and timely 

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

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 benefit from the specific 

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

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

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

regional offices, a specialty unit, or to an Enforcement group in the Home Office. 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 significantly 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 1,000 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.

In general, whistleblower tips that are specific, 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 

identifies individuals involved in the scheme, provides examples of particular fraudulent 

transactions, or points to non-public materials evidencing the fraud, the tip is more 

likely to be assigned to Enforcement staff for investigation. Tips that make blanket 

assertions or general inferences based on market events are less likely to be forwarded 

to or investigated by Enforcement staff.
WHISTLEBLOWER PROGRAM | 27

“Whistleblower 

tips that are specific, 

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.”

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 confidentiality requirements. 

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

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

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

the federal securities laws also are forwarded to OIEA. 

Assistance by OWB

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

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

the information is entered into the TCR System so it can be evaluated by OMI. 

Tips submitted by whistleblowers through the Commission’s online portal are 

automatically forwarded to OMI for evaluation. 

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

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

Additional information may be submitted through the online portal, with reference 

to the original TCR submission number (if known), or may be submitted directly 

to investigative staff if the whistleblower is working with staff on the matter. To 

the extent additional information is sent to OWB in hard-copy by mail or fax, the 

additional information is uploaded to the TCR System. Due to the increasing 

volume of additional information submitted in paper form to OWB, and the ready 

availability of electronic submissions, OWB no longer provides acknowledgement 

letters in response to mailed or faxed submissions. 
28 | U.S. SECURITIES AND EXCHANGE COMMISSION

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

INVESTOR PROTECTION FUND

Section 922 of 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.43 As required by statute, all payments are made out of this Fund, 

which is financed entirely through monetary sanctions paid to the SEC by securities 

law violators. No money has been taken or withheld from harmed investors to pay 

whistleblower awards. The Fund also is used to finance the operations of the suggestion 

program of the SEC’s Office of Inspector General.44 The suggestion program is intended 

for the receipt of suggestions from SEC employees for improvements in work efficiency, 

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.45

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 2019. 

 FY 2019

Balance of Fund at beginning of fiscal year $ 299,333,981.82 

Reversal of prior year sequestered amount46 $ 12,234,592.57 

Amounts deposited into or credited to Fund during fiscal year $ 156,519,496.36 

Amounts of interest receipts from investments during fiscal year $ 6,583,501.46

Current year sequestered amount46 $ (10,112,385.86)

Amounts paid from Fund during fiscal year to whistleblowers $ (141,976,223.37)

Reversal of obligations accrued in prior years $ 81,426,463.14

Amount disbursed to Office of the Inspector General during fiscal year $ (33,497.17)

Balance of Fund at end of fiscal year $ 403,975,928.95

46

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

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

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

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

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

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

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

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

46 Amounts relate to available resources temporarily reduced during the fiscal 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 fiscal year.
WHISTLEBLOWER PROGRAM | 29

Whenever the balance of the Fund falls below $300 million, a statutory replenishment 

mechanism is triggered. On March 31, 2019, the fund fell below $300 million. 

On April 30, 2019, the Fund was replenished in the amount of $156.5 million from 

monetary sanctions collected by the Commission between March 31, 2019 and 

April 11, 2019, which were not to be added to a disgorgement fund or otherwise 

distributed to victims of a violation of the securities laws. 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 financial statements for the Fund, including a balance sheet, 

income sheet, income statement, and cash-flow analysis. That information will be 

included in the Commission’s Agency Financial Report, which will be separately 

submitted to Congress.
30 | U.S. SECURITIES AND EXCHANGE COMMISSION
WHISTLEBLOWER PROGRAM | 31

*The category of “Other” indicates that the submitter identified the whistleblower TCR as not fitting into any allegation category that is listed on 

the questionnaire. The “Crypto Currency” allegation category was introduced during the fourth quarter of FY 2018.

APPENDIX A

WHISTLEBLOWER TIPS BY ALLEGATION TYPE

COMPARISON OF FISCAL YEARS 2016-2019

0

500

1,500

1,000

2,000

2019

2016

2017

2018

Not 

Reported

97 94 109

131

Corporate 

Disclosures 

and Financials

938 954

983

1,107

Insider

Trading

262 262

222 231

FCPA

210 202 200

238

Crypto 

Currency

289

Unregistered

Oerings

252

143 144 138

Manipulation

472 468

535

624

Market

Event

157

48

102

125

Municipal

Securities and 

Public Pension

67 67 57

35

Oering

Fraud

1,054

646

692

758

Other*

1,210

996

1,162

1,614

Trading and

Pricing

333

257 271

201
32 | U.S. SECURITIES AND EXCHANGE COMMISSION

*Approximately 3,262 WB TCRs were submitted in the United States or a U.S. territory during FY 2019, which constitutes approximately

 63 percent of the WB TCRs submitted during this period. In addition, approximately 1,471 WB TCRs, constituting approximately 28 percent 

of the WB TCRs submitted in FY 2019, were submitted with an unknown foreign or domestic geographical categorization or were submitted 

anonymously through counsel.

APPENDIX B

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

UNITED STATES AND ITS TERRITORIES, FISCAL YEAR 2019*

33

60

16

78

241

107

116

113

76

46

66

28

65

159

290

28

332

21

18

245

1

54

11

2

39

4

20

16

19

5

11

4

11

14

18

8

3

92

2

5

3

21

21

39

19

12

29

47

6

9

546

33

AK

AL

AR

AZ

CA

CO

CT

DC

DE

FL

GA

HI

IA

ID

IL

IN

KS

KY

LA

MA

MD

ME

MI

MN

MO

MS

MT

NC

ND

NE

NH

NJ

NM

NV

NY

OH

OK

OR

PA

PR

RI

SC

SD

TN

TX

UT

VA

VI

VT

WA

WI

WV

0 100 200 300 400 500 600
WHISTLEBLOWER PROGRAM | 33

*The number of WB TCRs submitted from abroad during FY 2019 were approximately 479, constituting approximately 9 percent of the WB TCRs submitted 

during this period.

44

4

3

7

20

1

2

2

1

7

4

7

2

1

3

2

1

4

2

4

27

1

4

4

4

10

44

5

1

1

1

1

2

13

1

1

1

1

15

4

1

2

1

1

28

1

1

AFGHANISTAN

ARGENTINA

AUSTRALIA

AUSTRIA

AZERBAIJAN

BAHAMAS

BANGLADESH

BELGIUM

BRAZIL

BRUNEI

BULGARIA

BURMA

CANADA

CAYMAN ISLANDS

CHILE

CHINA, PEOPLE'S REPUBLIC OF

COLOMBIA

COSTA RICA

CROATIA

CURACAO

CZECH REPUBLIC

DENMARK

EGYPT

ESWATINI

FINLAND

FRANCE

FRENCH POLYNESIA

GERMANY

GREECE

HONG KONG

HUNGARY

ICELAND

INDIA

ISRAEL

ITALY

JAMAICA

JAPAN

KAZAKHSTAN

LATVIA

LEBANON

LITHUANIA

LUXEMBOURG

MALAYSIA

MEXICO

NETHERLANDS

NEW ZEALAND

NIGERIA

NORWAY

PAKISTAN

PANAMA

PHILIPPINES

POLAND

PORTUGAL

ROMANIA

RUSSIA

SAUDI ARABIA

SINGAPORE

SOUTH AFRICA

SPAIN

SURINAME

SWEDEN

SWITZERLAND

TAIWAN

THAILAND

TUNISIA

TURKEY

UNITED KINGDOM

UKRAINE

UNITED ARAB EMIRATES

VIETNAM

32

1

3

2

2

1

4

2

2

71

1

5

2

2

2

22

1

1

1

3

0 10 20 30 40 50 60 70 80

13

1

8

APPENDIX C

WHISTLEBLOWER TIPS RECEIVED BY GEOGRAPHIC LOCATION

INTERNATIONAL, FISCAL YEAR 2019*


OFFICE OF THE WHISTLEBLOWER

Washington, DC