______________________________________________________________________________ 

UNITED STATES OF AMERICA 

Before the 

SECURITIES AND EXCHANGE COMMISSION

SECURITIES EXCHANGE ACT OF 1934 

Release No. 97438 / May 5, 2023

WHISTLEBLOWER AWARD PROCEEDING 

File No. 2023-55

______________________________________________________________________________ 

In the Matter of the Claims for Award

in connection with 

Redacted Redacted Redacted

Notice of Covered Action 

Redacted

ORDER DETERMINING WHISTLEBLOWER AWARD CLAIMS 

The Claims Review Staff (“CRS”) issued a Preliminary Determination recommending 

that: (1) (“Claimant 1”) receive a whistleblower award in the amount 

of %) of the monetary sanctions collected in (i) 

(“Covered Action”), 

(ii) 

(“Related Action 2”);2 (2) 

(“Claimant 2”) be denied a whistleblower award; and (3) 

percent ( 

(“Related Action 1”),1 and (iii) 

Redacted Redacted Redacted Redacted Redacted Redacted Redacted Redacted Redacted Redacted Redacted ***

1 Rule 21F-11(a) of the Securities Exchange Act of 1934 (“Exchange Act”) provides that, “If you are eligible 

to receive an award following a Commission action that results in monetary sanctions totaling more than 

$1,000,000, you also may be eligible to receive an award based on the monetary sanctions that are collected from a 

related action.” 17 C.F.R. § 240.21F-11(a). 2 The Preliminary Determination recommended that Related Action 1 and Related Action 2 (collectively, 

Redacted

“Related Actions”) be deemed “related actions” under Rules 21F-3(b)(1) and 
(“Claimant 3”) be denied a whistleblower award.

3 The award to Claimant 1 will result in a 

payment of approximately $279 million.4 

Claimant 1 provided written notice of his/her decision not to contest the Preliminary 

Determination. Claimant 2 and Claimant 3 filed timely responses contesting the Preliminary 

Determination. For the reasons discussed below, the CRS’s recommendations are adopted. 

I. Background 

A. The Covered Action and the Related Actions 

On the Commission brought the Covered Action in the 

(“Court”). The Covered Action charged 

(“Company”) with 

by engaging in 

The Covered Action alleged that

 The Covered Action also alleged 

that 

Redacted Redacted Redacted Redacted Redacted Redacted Redacted Redacted Redacted Redacted Redacted Redacted Redacted Redacted Redacted

On

Redacted

 the Court entered a final judgment against the Company that 

resolved the Covered Action. Among other things, the Company was ordered to pay 

disgorgement of and prejudgment interest of The disgorgement and 

prejudgment interest, which totaled has been paid in full. 

Redacted Redacted Redacted

In 

“Other Agency”) 

brought the Related Actions in the Court. The Other Agency’s 

related to the same the Commission 

Redacted Redacted Redacted Redacted Redacted

charged in the Covered Action.5 

3 The Preliminary Determination concluded that because Claimant 2 and Claimant 3 were not eligible for 

awards in the Covered Action, they were not eligible for awards in the Related Actions. 4 The CRS also preliminarily determined to recommend that the award application of one other claimant be 

denied. That claimant did not submit a request for reconsideration and, as such, the Preliminary Determination with 

respect to this claimant became the Final Order of the Commission, pursuant to Rule 21F-10(f). 

Redacted Redacted

5 The Other Agency charged the Company for misconduct 

however, unlike the Commission, the Other Agency did not charge the Company for 

2 
Related Action 1

 These monetary sanctions have been 

paid in full. In Related Action 2 

Redacted Redacted Redacted Redacted Redacted Redacted Redacted Redacted Redacted Redacted Redacted Redacted

On

Redacted

 the Office of the Whistleblower (“OWB”) posted the Notice of 

Covered Action on the Commission’s public website inviting claimants to submit whistleblower 

award applications within 90 days.7 Claimants filed timely whistleblower award claims. 

B. The Preliminary Determination 

The CRS issued a Preliminary Determination

Redacted

8 recommending that the Commission: 

percent ( ***grant Claimant 1 an award equal to %) of the monetary sanctions 

collected in the Covered Action and the Related Actions; and deny the award claims of Claimant 

2 and Claimant 3 in the Covered Action and the Related Actions.9 

C. The Preliminary Determination as to Claimant 2 

The Preliminary Determination recommended that the Commission deny Claimant 2’s 

claim because none of Claimant 2’s information led to the successful enforcement of the 

Covered Action within the meaning of Section 21F(b)(1) of the Exchange Act and Rules 21F3(a)(3) and 21F-4(c) thereunder. The CRS preliminarily concluded that Claimant 2’s 

information did not either (1) cause the Commission to commence an examination, open or 

Redacted Redacted Redacted Redacted Redacted

7 See Exchange Act Rule 21F-10(a), 17 C.F.R. § 240.21F-10(a). 8 See Exchange Act Rule 21F-10(d), 17 C.F.R. § 240.21F-10(d). 9 The record supporting the Preliminary Determination included the declaration (“Declaration”) of one of the 

Division of Enforcement (“Enforcement”) attorneys who was assigned to the investigation that led to the Covered 

Action (“Investigation”). See Exchange Act Rule 21F-12(a), 17 C.F.R. § 240.21F-12(a). 

3 
reopen an investigation, or inquire into different conduct as part of a current Commission 

examination or investigation under Rule 21F-4(c)(1); or (2) significantly contribute to the 

success of a Commission judicial or administrative enforcement action under Rule 21F-4(c)(2). 

The CRS also preliminarily concluded that Rule 21F-4(c)(3) did not apply. Under Rule 

21F-4(c)(3), an individual provides original information that led to the successful enforcement of 

a judicial or administrative enforcement action where: (1) the individual reported “information 

through an entity’s internal whistleblower, legal, or compliance procedures for reporting 

allegations of possible violations of law before or at the same time [the individual] reported them 

to the Commission”; (2) “the entity later provided [the individual’s] information to the 

Commission, or provided results of an audit or investigation initiated in whole or in part in 

response to information [the individual] reported to the entity”; and (3) “the information the 

entity provided to the Commission satisfies either” Rule 21F-4(c)(1) or Rule 21F-4(c)(2).10 

Additionally, under Rule 21F-4(c)(3), the individual “must also submit the same information to 

the Commission in accordance with the procedures set forth in [Rule 21F-9] within 120 days of 

providing it to the entity.” 

D. Claimant 2’s Response to the Preliminary Determination 

Claimant 2 submitted a timely, written response contesting the Preliminary 

Determination.11 Claimant 2 argues that he/she qualifies for an award under Rule 21F-4(c)(1). 

Claimant 2 speculates that his/her allegations about 

least partially motivated the Commission’s decision to convert its matter under inquiry regarding 

the Company (“MUI”) into the Investigation. Claimant 2 also argues that he/she qualifies for an 

award under Rule 21F-4(c)(3) because he/she reported information to the Commission within 

120 days of reporting it to the Company. 

E. The Preliminary Determination as to Claimant 3 

The Preliminary Determination recommended that the Commission deny Claimant 3’s 

claim because none of Claimant 3’s information led to the successful enforcement of the 

Covered Action within the meaning of Section 21F(b)(1) of the Exchange Act and Rules 21F3(a)(3) and 21F-4(c) thereunder. The CRS preliminarily concluded that Claimant 3’s 

information did not either (1) cause the Commission to commence an examination, open or 

reopen an investigation, or inquire into different conduct as part of a current Commission 

examination or investigation under Rule 21F-4(c)(1); or (2) significantly contribute to the 

success of a Commission judicial or administrative enforcement action under Rule 21F-4(c)(2). 

10 Exchange Act Rule 21F-4(c)(3), 17 C.F.R. § 240.21F-4(c)(3). 11 See Exchange Act Rule 21F-10(e), 17 C.F.R. § 240.21F-10(e). 

Claimant 2 argues that his/her information caused the Commission to open the Investigation. 

at 

Redacted

4 
Redacted

The CRS preliminarily determined that Claimant 3’s information concerned 

that was unrelated to the Investigation and the conduct charged in the Covered Action. 

Redacted

F. Claimant 3’s Response to the Preliminary Determination 

Claimant 3 submitted a timely, written response contesting the Preliminary 

Determination.12 Claimant 3 alleges that the charged in the Covered Action is 

the same that Claimant 3 identified to the Commission. Claimant 3 

Redacted Redacted

states that he/she provided extensive information and documentation about the Company’s illicit 

activities. 

Redacted

Claimant 3 argues that even though his/her information concerned alleged misconduct 

Redacted

from and the Covered Action concerned misconduct from Claimant 

3’s information was still relevant to the Commission and the charges in the Covered Action. 

II. Analysis 

A. Claimant 1 

The record demonstrates that Claimant 1 voluntarily provided original information to the ***

Commission, and Claimant 1’s original information led to the successful enforcement of the 

Covered Action.14 The record reflects that: (1) Claimant 1’s information was significant, as it 

caused Enforcement staff responsible for the Covered Action (“Staff”) to expand the 

Investigation from (2) Claimant 1’s 

Redacted

information saved the Commission significant time and resources; and (3) Claimant 1 provided 

substantial, ongoing assistance, which included multiple written submissions, communications, 

12 Id. 

Redacted Redacted Redacted Redacted Redacted Redacted Redacted Redacted Redacted Redacted Redacted Redacted Redacted Redacted

See Exchange Act Section 21F(b)(1), 15 U.S.C. § 78u-6(b)(1); Exchange Act Rule 21F-3(a), 17 C.F.R. 

§ 240.21F-3(a). 

5 

14 
and interviews. While Claimant 1’s information was important, it was submitted after the 

Investigation had already been opened and after Staff had already become aware of potential 

Redacted

misconduct by the Company Further, Claimant 1’s specific information only related 

to certain of the conduct that the Commission ultimately charged in the Covered Action. 

In light of these considerations and the relevant factors specified in Rule 21F-6,

Redacted

percent ( ***

15 it is 

appropriate that Claimant 1 receive an award of %) of the monetary 

sanctions collected in the Covered Action. 

We also find that the Related Actions constitute “related actions” under Rules 21F3(b)(1) and 

and 

Redacted Redacted

 and that Claimant 1 has satisfied the requirements of Rules 21F-3(b)(2) 

for related action awards. The Related Actions were based in part on the same 

original information that Claimant 1 voluntarily provided to the Commission. Specifically, 

Claimant 1 voluntarily provided original information to the Commission, which was also 

provided to the Other Agency, and Claimant 1’s information led to the successful enforcement of 

the Related Actions. 

In light of the considerations discussed above, it is appropriate that Claimant 1 receive an 

Redacted

percent ( ***award of %) of the monetary sanctions collected in the Related Actions. 

B. Claimant 2 

We deny an award to Claimant 2. To qualify for an award under Section 21F of the 

Exchange Act, a whistleblower must voluntarily provide the Commission with original 

information that leads to the successful enforcement of a covered action.16 Claimant 2 did not 

provide the Commission with such information. Because Claimant 2 is not eligible for an award 

in the Covered Action, Claimant 2 is not eligible for an award in the Related Actions.17 

Claimant 2’s information did not either (1) cause the Commission to commence an 

examination, open or reopen an investigation, or inquire into different conduct as part of a 

current Commission examination or investigation;18 or (2) significantly contribute to the success 

15 In determining the amount of the award to Claimant 1, we considered the following factors set forth in Rule 

21F-6 as they apply to the facts and circumstances of Claimant 1’s application: (1) the significance of information 

provided; (2) the assistance provided; (3) the 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. 16 Exchange Act Section 21F(b)(1), 15 U.S.C. §78u-6(b)(1). 17 See Exchange Act Rule 21F-3(b)(1), (b)(2), 17 C.F.R. § 240.21F-3(b)(1), (b)(2); Exchange Act Rule 21F11(a), 17 C.F.R. § 240.21F-11(a). 18 See Exchange Act Rule 21F-4(c)(1), 17 C.F.R. § 240.21F-4(c)(1). 

6 
of a Commission judicial or administrative enforcement action.19 We credit the Declaration, 

provided under penalty of perjury, which confirms that Claimant 2’s information did not advance 

or impact the Investigation. None of Claimant 2’s information was used in, nor had any impact 

on, the charges brought in the Covered Action. 

Redacted

Further, the Covered Action did not contain any 

allegations which was the subject of Claimant 2’s information. 

Redacted

Claimant 2 contests these conclusions, asserting that his/her information about alleged 

at least partially motivated the decision for the MUI to be 

converted into the Investigation. Claimant 2’s arguments about this point are largely focused on 

the chronology of events related to the Commission’s investigative work and how such events 

were purportedly affected by Claimant 2’s information. Such arguments, however, are nothing 

more than speculation and are belied by the record. 

As confirmed by the Declaration, in Staff opened the MUI based on 

 Staff opened the MUI to investigate whether the Company

 Shortly after opening the MUI, Staff for 

Redacted Redacted Redacted Redacted Redacted ***

the first time obtained and reviewed information that Claimant 2 had submitted to the 

Commission in On or about Staff sent the Company 

Redacted Redacted Redacted

a voluntary request seeking information and documents about certain matters, including alleged 

 based on Claimant 2’s allegations. 

On or about

Redacted

 the MUI was converted to the Investigation. A supplemental 

declaration (“Supplemental Declaration”) of one of the Enforcement attorneys who was assigned 

Redacted

to the Investigation, which we credit, confirms under penalty of perjury that Staff converted the ***

MUI to the Investigation after Staff received a presentation from the Company on or about 

(“Company Presentation”). During the Company Presentation, Staff learned new 

information from the Company that was relevant to Staff’s inquiry into the Company. The 

Company Presentation did not concern any of Claimant 2’s information or allegations. 

Redacted

The 

Company Presentation also did not concern any alleged misconduct Accordingly, 

none of Claimant 2’s information had any effect on the conversion of the MUI to the 

Investigation. 

Later in 

Redacted

Staff contacted Claimant 2’s counsel to discuss Claimant 2’s 

allegations; during that discussion, Staff did not learn any new information from Claimant 2’s 

Redacted

counsel. On or about Staff obtained a Formal Order of Investigation. The 

Declaration and Supplemental Declaration both confirm that Claimant 2’s information had no 

See Exchange Act Rule 21F-4(c)(2), 17 C.F.R. § 240.21F-4(c)(2). 

7 

19 
20 

bearing on the opening of the MUI, the opening of the Investigation, or the issuance of the 

Formal Order of Investigation. 

Additionally, Rule 21F-4(c)(3) does not apply here. First, Claimant 2 did not report 

his/her information through the Company’s internal whistleblower, legal, or compliance 

procedures for reporting allegations of possible violations of law before or at the same time that 

Claimant 2 reported them to the Commission. 

Redacted Redacted Redacted

Instead, Claimant 2 first submitted his/her 

Redacted Redacted

information to the Commission in Claimant 2 then reported his/her information to 

the Company at the end of Claimant 2 then sent a supplemental submission to the 

Commission in This supplemental submission was comprised of copies of an 

anonymous email that Claimant 2 sent to the Company in and email 

***

that Claimant 2 received in response from the Company. The substance of Claimant 2’s

Redacted

 information was the same as the substance of Claimant 2’s information. Thus, 

***

Claimant does not satisfy the temporal requirements of Rule 21F-4(c)(3).20 

Second, the Company did not initiate an audit or investigation in whole or in part in 

response to the information Claimant 2 reported to the Company. As confirmed by the 

Declaration, the Company began internal investigative work not in response to any tip or other 

information provided by Claimant 2, but rather in response to two internal complaints the 

Company received in regarding alleged

 There is no support in the record for Claimant 2’s 

Redacted Redacted Redacted Redacted Redacted

supposition that Claimant 2’s information prompted the Company to undertake investigative 

Redacted

work because email from the Company stated that

 thereby allegedly suggesting that the Company was 

in the process of investigating Claimant 2’s allegations.21 

Claimant 2’s other arguments are unavailing. Claimant 2’s complaint that the record 

Redacted

does not suitably explain why Claimant 2’s allegations about misconduct lacked merit 

is misguided. As confirmed by the Declaration, Staff found no merit to Claimant 2’s allegations 

Claimant 2 asserts that being required to report his/her information to the Company first before coming 

forward to the Commission would have forced him/her to expose himself/herself to retaliation at the cost of making 

a report. Such concerns, however, were not present here. Claimant 2 indicated in his/her whistleblower award 

application that 

Redacted Redacted Redacted Redacted

In the alternative, Claimant 2 argues that the Commission should exercise its discretion to waive any timing 

requirement under Rule 21F-4(c)(3) that Claimant 2 report internally before reporting to the Commission. In light 

of the factual record in this matter, there is no reason to waive the timing requirement of Rule 21F-4(c)(3) in our 

discretion or to invoke our Section 36(a) exemptive authority, as Claimant 2 does not satisfy the other requirements 

under Rule 21F-4(c)(3). 

8 

21 
about alleged misconduct

Redacted

 after reviewing information and documentation supplied by 

Redacted Redacted

Claimant 2 and the Company. Neither the Covered Action nor the Related Actions concerned 

Redacted

any misconduct Further, Claimant 2’s complaint that the allegations related to 

—which prompted Staff to investigate the Company—purportedly lacked legitimacy is 

irrelevant. Regardless of the veracity of the allegations, those allegations are what 

prompted Staff to begin its investigative work into the Company, not Claimant 2’s information. 

Further, Claimant 2’s unsupported assertion that his/her information revealed important 

Redacted

information about how the Company that was also present in the Covered Action 

is belied by the Declaration. The Declaration confirms that none of Claimant 2’s information 

was used in, nor had any impact on, the charges brought in the Covered Action. 

Claimant 2 points to a prior final order in which we awarded a claimant even though 

there was “not a strong nexus between the [c]laimant’s information” and the resulting charges in 

the covered action.22 The specific facts involved in that other final order, however, are not 

comparable to the facts involved here. Unlike the other final order, Claimant 2’s information did 

Claimant 2’s information regarding alleged misconduct led the Commission to begin 

an investigation that revealed misconduct 

not prompt the Commission to begin its investigation of the Company; further, nothing about 

Redacted Redacted

Finally, Claimant 2 complains about the alleged completeness of the record and requests 

that the Commission provide Claimant 2 with certain investigative files, including the opening 

Redacted ***

narrative for the Investigation, the voluntary request that was sent to the Company in 

 and third-party communications concerning Claimant 2’s information.23 However, 

Claimant 2 is not entitled to these extra-record materials. We have appropriately considered all 

materials contemplated by the whistleblower program rules in reaching our conclusion to deny 

Claimant 2 an award.24 

22 See Order Determining Whistleblower Award Claim, Exchange Act Rel. No. 91933 (May 19, 2021). 23 Claimant 2 states that he/she made a Freedom of Information Act (“FOIA”) request for such materials as 

Redacted

part of his/her whistleblower award application submitted to OWB in FOIA requests must be submitted 

to the Commission’s Office of FOIA Services (“OFS”), the centralized unit that handles all FOIA requests for the 

Commission and whose website provides procedures on submitting requests directly to OFS. See Order 

Determining Whistleblower Award Claim, Exchange Act Rel. No. 95714 (Sept. 9, 2022) (same). 24 The whistleblower program rules state that the record upon which an award determination is made shall 

consist of sworn declarations provided by the relevant Commission staff, in addition to the publicly available 

materials related to the Covered Action, the claimant’s tip, the claimant’s award application, and any other materials 

timely submitted by the claimant in response to the Preliminary Determination. See Exchange Act Rule 21F-12(a), 

17 C.F.R. § 240.21F-12(a). There is no basis to disregard Rule 21F-12(a) and expand the record to include the 

Commission’s law enforcement files (as requested by Claimant 2), which is generally prohibited by Rule 21F-12(b). 

See Exchange Act Rule 21F-12(b), 17 C.F.R. § 240.21F-12(b) (“These rules do not entitle claimants to obtain from 

the Commission any materials (including any pre-decisional or internal deliberative process materials that are 

prepared exclusively to assist the Commission in deciding the claim) other than those listed in paragraph (a) of this 

9 
C. Claimant 3 

We deny an award to Claimant 3. To qualify for an award under Section 21F of the 

Exchange Act, a whistleblower must voluntarily provide the Commission with original 

information that leads to the successful enforcement of a covered action.25 Claimant 3 did not 

provide the Commission with such information. Because Claimant 3 is not eligible for an award 

in the Covered Action, Claimant 3 is not eligible for an award in the Related Actions.26 

Claimant 3’s information did not either (1) cause the Commission to commence an 

examination, open or reopen an investigation, or inquire into different conduct as part of a 

current Commission examination or investigation;27 or (2) significantly contribute to the success 

Redacted Redacted Redacted Redacted Redacted Redacted Redacted Redacted Redacted Redacted ***

of a Commission judicial or administrative enforcement action.28 We credit the Declaration, 

provided under penalty of perjury, which confirms that Claimant 3’s information concerned 

 that was unrelated to the Investigation and the conduct charged in the 

Covered Action. purportedly transpired from when 

Claimant 3

 However, the 

 investigated by Staff and charged in the Covered Action concerned different misconduct 

that transpired from

 Claimant 3 had no current information about the 

Company or any conduct it engaged in Additionally, Staff did not open the 

Investigation based on Claimant 3’s information. Claimant 3’s information was not used in, and 

did not have any impact on, the charges brought by the Commission in the Covered Action. 

None of Claimant 3’s arguments demonstrate why we should reach a different 

Redacted

conclusion. There was no connection between Claimant 3’s and the

 charged in the Covered Action. 

Redacted

Nothing in the record supports Claimant 3’s 

contention that Claimant 3’s alleged was the same misconduct 

Redacted

charged by the Commission and the Other Agency merely because there was temporal overlap 

Redacted

with the misconduct that the Other Agency charged (i.e., from 

Claimant 3’s other arguments are of no import. While the Declaration indicates that 

Redacted

Claimant 3 provided information about a Company subsidiary called 

(“Subsidiary”), the Declaration does not state that Claimant 3 solely provided information about 

section [i.e., Rule 21F-12(a)].” 25 Exchange Act Section 21F(b)(1), 15 U.S.C. §78u-6(b)(1). 26 See Exchange Act Rule 21F-3(b)(1), (b)(2), 17 C.F.R. § 240.21F-3(b)(1), (b)(2); Exchange Act Rule 21F11(a), 17 C.F.R. § 240.21F-11(a). 27 See Exchange Act Rule 21F-4(c)(1), 17 C.F.R. § 240.21F-4(c)(1). 28 See Exchange Act Rule 21F-4(c)(2), 17 C.F.R. § 240.21F-4(c)(2). 

10 
29 

the Subsidiary and did not provide information about anything else, contrary to Claimant 3’s 

contentions. Further, there is no support in the record for Claimant 3’s assertion that the 

Preliminary Determination implicitly acknowledged that Claimant 3 provided original 

information merely because it did not specifically state that Claimant 3’s information was not 

original information. We conclude that there is nothing in the record that indicates that Claimant 

3 provided any original information to the Commission that led to or significantly contributed to 

the underlying Covered Action. 

Claimant 3 also takes issue with the Declaration’s statement that Claimant 3’s 

information about did not advance 

Redacted

the Commission’s or the Other Agency’s investigations and had no bearing on the Covered 

Action or the Related Actions. According to the Declaration, the provided by 

Claimant 3 were 

 did not point to any additional evidence or advance the Commission’s or the Other 

Agency’s investigations. Further, Claimant 3’s information about

 was not useful, as was not involved in the conduct 

Redacted Redacted Redacted Redacted Redacted Redacted

charged in the Covered Action. 

There is also no merit to the other arguments Claimant 3 raised in his/her response 

contesting the Preliminary Determination.

29 As such, we conclude that it is appropriate to deny 

an award to Claimant 3. 

Claimant 3 complains that his/her initial 

Redacted

submission of information was not initially properly 

categorized by the Commission. After the Commission received Claimant 3’s tip, it was categorized with a 

disposition of “no further action” (“NFA”) because Claimant 3’s allegations were vague and/or insubstantial. 

However, Staff subsequently reviewed Claimant 3’s initial submission during Staff’s investigative work, reviewed 

all of Claimant 3’s ensuing submissions of information during the Investigation, and met with Claimant 3 and ***

his/her counsel during in-person meetings in According to Staff, none of the information provided by 

Claimant 3 at any point in time advanced or impacted the Investigation or Covered Action. Claimant 3 also argues 

that the Declaration incorrectly asserted that the individuals Claimant 3 identified as potentially responsible for 

certain alleged misconduct no longer worked at the Company at the time of the Investigation. Claimant 3 alleges 

that many of the executives he/she identified to the Commission were still signing Company filings during the 

course of the Investigation. Despite Claimant 3’s assertions, the Declaration affirms that none of the individuals that 

Claimant 3 identified were involved in the conduct investigated by Staff or charged in the Covered Action. Finally, 

Claimant 3’s contention that he/she displayed great dedication and perseverance in providing his/her information is 

immaterial to our determination that Claimant 3 did not provide qualifying information that would entitle him/her to 

an award. The record conclusively demonstrates that none of Claimant 3’s information was used in, nor had any 

impact on, the charges brought by the Commission in the Covered Action. 

11 
III. Conclusion

Redacted

Accordingly, it is hereby ORDERED that:

percent ( ***

(1) Claimant 1 shall receive an award of

%) of the monetary sanctions collected in the Covered Action and the 

Related Actions; and (2) the whistleblower applications of Claimant 2 and Claimant 3 in 

connection with the Covered Action and the Related Actions be, and hereby are, denied. 

By the Commission. 

Vanessa A. Countryman

 Secretary 

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