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PUBLIC VERSION 


UNITED STATES OF AMERICA 


before the 


COMMODITY FUTURES TRADING COMMISSION 


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In the Matter of: 

Whistleblower Award Application of 

·("Applicant"): 

Form WB-APP 

CFTC Whistleblower Award 

Determination No. 16-WB-06 

ORDER 

Attached is the Final Determination of the Commodity Futures Trading Commission 

("Commission") pertaining to the whistleblower award application of 

("Applicant"), submitted on Fonn WB-APP , in response to the Commission's 

Notice of Covered Action No. regarding 

Pursuant to the Comn1ission 's Whistleblower Rules ("Rules"), the Commission delegated 

the authority to make whistleblower award determinations to the Whistleblower Award 

Determination Paud ("Pa11d"). 17 C.F.R. § l 65. l 5(b). Therefore, the Panel's award 

detennination is the final detennination of the Commission. 

As set f01ih in the attached, it is the Final Commission Determination and Order ofthe 

Commission that the Applicant's whistleblower award application shall he granted. After giving 

due consideration ofthe factors set forth in Rule 165.9, 17 C.F.R. § 165.9, the Panel determined 

that the award amount should be % of the amount of the monetmy sanctions collected in 

. Accordingly, the Applicant shall receive a whistleblower award in the 

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PUBLIC VERSION 


amount of 

In accordance with 7 U.S.C. § 26(f) and 17 C.F.R. § 165.13, if you wish to appeal the 

Final Commission Dete1mination and Order, you must appeal to the appropriate court of appeals 

of the United States no more than 30 days after this Final Order of the Commission is issued. 

Decision Issued: ~'l 1, c: l f '2016 

Robert Sidman 

Deputy Secretary ofthe Commission 

Commodity Futures Trading Commission 

1155 21st Street, N. W. 

Washington, DC 20581 

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UNITED STATES OF AMEIUCA 


before the 


COMMODITY FUTURES TRADING COMMISSION 


In the Matter of: 

Whistleblowcr Award Application of 

("Applicant"): 

Form WB-APP 

CFTC Whistleblower Award 

) Determination No. 16-WB-06 

) 

) 

) 

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) 

PUBLIC VERSION 


WHISTLEBLOWER A WARD DETERMINATION 

Before the Whistleblower Award Determination Panel ("Panel") of the Commodity 

Futures Trading Commission (''Commission'') is the whistleblower award application of 

("Applicant"), submitted on Form WB-APP . The 

Applicant submitted the award application in response to the Commission's Notice of Covered 

Action No. regarding 

1. For reasons set forth 

below, the Applicanfs application is granted, and the Applicant shall be t,ri·anted an award of 

% of the amount of the monetary sanctions collected 1n , which results 

in an award of 

IT IS HEREBY DETERMINED that: 

1. The Applicimt's award application is granted because the Applicant meets the 

requirements of Section 23 ofthe Commodity Exchange Act, 7 U.S.C. § 26 (2012\ and the 

Commission's Whistlebio-wcr Rules ("Rules"), 17 C.F.R. § 165 (2015). The Applicant 

voluntarily provided the Commission \vith original information that led to the successful 

enforcement of a covered action. The Applicant's information was sufficiently 

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PUBLIC VJl:RSION 

specific, credible, and timely to cause the Commission to open an investigation. The 

Commission then brought a successful action, , based in 

part on conduct that was the subject ofthe Applicant's original information. 

2. The Applicant also meets all eligibility requirements for an award. See 17 C.F.R. 

§§ 165.5(b), 165.6. The Applicant submitted a Form TCR, is the original source ofthe 

information, and provided assistance to Commission staff during the course of the investigation 

leading up to . Further, the Applicant does not fall into any ofthe 

categories ofindividuals ineligible for an award, as set forth in Rule 165.6(a)i 17 C.F .R. 

§ 165.6(a). 

3. The Panel concludes that the award should be % ofthe amount of the total 

monetary sanctions collected in . In arriving at this award amount, the 

Panel applied the factors set forth in Rule 165.9, 17 C.F.R. § 165.9, in relation to the facts and 

circumstances ofthe Applicant's award application. To this end, the Panel considered the 

significance of the Applicant's information, the degree of assistance the Applicant 

provided to Commission staff during the course ofthe investigation, and the 

Commission's programmatic and law enforcement interests . 

. Finally, the Panel believes this award appropriately recognizes the significance of 

the information the Applicant provided to the Commission, and the size of the award should 

serve to incentivizc future whistleblowers to come forth with high quality information while not 

creating perverse incentives possible as a result of oversize awards. 

a. The Applicant's information caused the Commission to commence its 

investigation, 

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b. During the investigation, the Applicant was forthcoming and 

cooperative, and provided assistance and documents upon request. 

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PUBLIC VERSION 


e. The Applicant did not participate in or have involvement in the violations 

that support the action. In addition, nothing in the record indicates the Applicant 

pmiicipatcd in or interfered with internal compliance and repo1iing systems. The 

Applicant did not unreasonably delay reporting the information to the Commission. 

4. Accordingly, upon due consideration of the factors listed in Rule 165.9, 17 C.F.R. 

§ 165.9, it is hereby DETERMINED that the Applicant shall receive an award of % ofthe 

amount ofthe monetary sanctions collected in 

Whistleblower Award Determination Panel 

Commodity Futures Trading Commission 

1155 21st Street, N.W. 

Washington, DC 20581 

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