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The SEC announced another whistleblower bounty that paid nearly $3.5 million to four individuals.  Jointly, three whistleblowers provided information to the SEC that led to the staff opening an investigation. The investigation led to a successful enforcement action by the SEC. Additionally, that information and investigation led to another agency opening its own investigation, culminating in a separate enforcement action.  The fourth whistleblower used publicly available information to offer additional insights to the SEC. This information and analysis showed additional allegations to the staff that furthered the investigation. However, this whistleblower was “an outsider not affiliated with the Company.”  The individual’s analysis from public information was highly detailed and took considerable time and effort to research and collate, such as changes in the company’s stock pricing. The report submitted to the SEC took approximately seven weeks to complete.The SEC announced another whistleblower bounty that paid nearly $3.5 million to four individuals.

Jointly, three whistleblowers provided information to the SEC that led to the staff opening an investigation. The investigation led to a successful enforcement action by the SEC. Additionally, that information and investigation led to another agency opening its own investigation, culminating in a separate enforcement action. Continue reading

The Commodities Futures Trading Commission (CFTC) recently awarded a bounty of $10 million to a whistleblower who offered original information voluntarily. The information led to the opening of an investigation and a subsequent successful enforcement action. According to the order, the individual provided the information properly via a Form TCR that involved information previously unknown to the CFTC, and in violation of the Commodity Exchange Act (CEA.) The whistleblower was under no obligation to provide this information, and provided it at the outset of the investigation, when the CFTC was unaware of the ongoing conduct.The Commodities Futures Trading Commission (CFTC) recently awarded a bounty of $10 million to a whistleblower who offered original information voluntarily. The information led to the opening of an investigation and a subsequent successful enforcement action.

According to the order, the individual provided the information properly via a Form TCR that involved information previously unknown to the CFTC, and in violation of the Commodity Exchange Act (CEA.) The whistleblower was under no obligation to provide this information, and provided it at the outset of the investigation, when the CFTC was unaware of the ongoing conduct. Continue reading

The Commodity Futures Trading Commission (CFTC) has awarded a $625,000 bounty to four whistleblowers who provided information and assistance in an investigation.  A total of nine claimants submitted award applications for this enforcement action. Of that number, only four received awards. Claimants 2, 3, 4, and 6 received bounties from the civil monetary penalties levied against the two defendants involved in the enforcement action. Claimant 4 offered the highest level of assistance and cooperation and received the largest portion of the bounty. All four offered substantial assistance that included providing names and other information which supported the Commission's action against the defendants.  The Claims Review Staff (CRS) decided to deny award applications of claimants 1, 5, 7, 8, and 9. These claimants failed to meet the program’s requirements. Specifically, CRS found that Claimant 1’s wasn't voluntary, because it was provided after they received multiple requests including a subpoena from CFTC staff.  After receiving the preliminary determination, Claimant 1 requested the records supporting that determination. CFTC Whistleblower staff provided the material shortly thereafter. Claimant 1 then submitted a letter contesting the preliminary determination. Because this claimant could not offer any new information to support their position, and nothing in the record indicated the voluntary submission of information, the request was again denied. This claimant provided the information only after multiple requests from CFTC. Therefore, the claimant was not eligible to receive an award in this case.The Commodity Futures Trading Commission (CFTC) has awarded a $625,000 bounty to four whistleblowers who provided information and assistance in an investigation.

A total of nine claimants submitted award applications for this enforcement action. Of that number, only four received awards. Claimants 2, 3, 4, and 6 received bounties from the civil monetary penalties levied against the two defendants involved in the enforcement action. Claimant 4 offered the highest level of assistance and cooperation and received the largest portion of the bounty. All four offered substantial assistance that included providing names and other information which supported the Commission’s action against the defendants. Continue reading

The SEC has awarded $3M to three different whistleblowers for assisting with three distinct covered actions in three separate orders.  1. In the first order, the Claims Review Staff (CRS) awarded a bounty of $1.5 million to an individual who provided original information and voluntarily gave assistance to SEC staff that led to a successful covered action.  2. In the second order, CRS awarded a $1 million bounty to an individual who also voluntarily offered original information that led the SEC to a successful covered enforcement action. In this case, the whistleblower also assisted SEC staff, including multiple interviews.  3. The third order saw a bounty of $400,000 to a whistleblower who first reported their concerns internally, leading to a ceasing of the wrongful activity. The individual subsequently reported the information to the SEC, leading to the opening of an investigation. Over the course of the investigation, the whistleblower met with SEC Enforcement staff, offering additional information and continued assistance. Ultimately, the charges in the covered enforcement action would “bear a close nexus” to the whistleblower’s stated allegations.The SEC has awarded $3M to three different whistleblowers for assisting with three distinct covered actions in three separate orders.

1. In the first order, the Claims Review Staff (CRS) awarded a bounty of $1.5 million to an individual who provided original information and voluntarily gave assistance to SEC staff that led to a successful covered action. Continue reading

The SEC has again given an award to a whistleblower. This time it totals $3.5 million, and comes after multiple instances of support from the individual.  The whistleblower’s contribution prompted SEC staff to investigate more possible securities violations. This made the investigation easier for the SEC staff, which saved them time and resources.  The additional information also helped with the whistleblower’s discussion of settlement. Not one, but two SEC enforcement actions were successful as a result of the whistleblower’s assistance and cooperation. The second enforcement action came from the same “nucleus of operative facts”  as the first action.The SEC has again given an award to a whistleblower. This time it totals $3.5 million, and comes after multiple instances of support from the individual.

The whistleblower’s contribution prompted SEC staff to investigate more possible securities violations. This made the investigation easier for the SEC staff, which saved them time and resources. Continue reading

Most whistleblowers are keen to keep their activity concealed and private until the information becomes public. In an unusual twist, one whistleblower decided to publish a research report online detailing the fraudulent activity of a company and that of its CEO prior to notifying the SEC of the fraud.  Within days of sharing this information online, the whistleblower then shared the same information with the SEC. The individual was persistent in reaching out to SEC staff about this information. Their continued contact led to the SEC opening an investigation that resulted in a successful enforcement action. This whistleblower was an outsider, not an employee of the company.  Without admitting or denying the findings, the Company and its CEO consented to the SEC’s order that required the Company to pay restitution as well as other remedies Ultimately, defrauded investors saw the return of millions of their dollars.Most whistleblowers are keen to keep their activity concealed and private until the information becomes public. In an unusual twist, one whistleblower decided to publish a research report online detailing the fraudulent activity of a company and that of its CEO prior to notifying the SEC of the fraud.

Within days of sharing this information online, the whistleblower then shared the same information with the SEC. The individual was persistent in reaching out to SEC staff about this information. Their continued contact led to the SEC opening an investigation that resulted in a successful enforcement action. This whistleblower was an outsider, not an employee of the company. Continue reading

Through three orders, the SEC issued awards to four people that totaled over $40 million.  In the first proceeding, the SEC awarded two individuals a bounty of $37 million that provided crucial evidence leading to the success of the covered action. One individual helped SEC staff understand the evidence provided, and led to additional relevant information. The continuing assistance of both gave staff more information that helped to advance the investigation. Another governmental agency was involved with this action with its own separate “covered action.” Both whistleblowers received 50% of the bounty amount. In the second proceeding, the SEC awarded one individual $1.8 million for the new information they provided that saw SEC staff open a new investigation into misconduct. The individual quickly offered an internal report, and continued to provide SEC staff with information, documentation, and other assistance throughout the investigation. Charges in the affiliated covered action were a direct result of this individual’s contributions, which caused them to suffer hardships as a result. In the third proceeding, a whistleblower received an SEC bounty of $1.5 million for information and assistance in an existing investigation that led to a successful enforcement action. As with the previous two, this individual gave continued and substantial assistance to SEC staff throughout the investigation. This whistleblower provided new information that saved staff time and resources and helped staff to understand the issues involved.Through three orders, the SEC issued awards to four people that totaled over $40 million.

  • In the first proceeding, the SEC awarded two individuals a bounty of $37 million that provided crucial evidence leading to the success of the covered action. One individual helped SEC staff understand the evidence provided, and led to additional relevant information. The continuing assistance of both gave staff more information that helped to advance the investigation. Another governmental agency was involved with this action with its own separate “covered action.” Both whistleblowers received 50% of the bounty amount.
  • In the second proceeding, the SEC awarded one individual $1.8 million for the new information they provided that saw SEC staff open a new investigation into misconduct. The individual quickly offered an internal report, and continued to provide SEC staff with information, documentation, and other assistance throughout the investigation. Charges in the affiliated covered action were a direct result of this individual’s contributions, which caused them to suffer hardships as a result.
  • In the third proceeding, a whistleblower received an SEC bounty of $1.5 million for information and assistance in an existing investigation that led to a successful enforcement action. As with the previous two, this individual gave continued and substantial assistance to SEC staff throughout the investigation. This whistleblower provided new information that saved staff time and resources and helped staff to understand the issues involved.

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The Securities and Exchange Commission has kept busy, even through the holidays. On January 10th, 2022, the SEC put out a press release announcing that three more people have received bounties after working with SEC staff to identify and discontinue wrongdoing in the financial sector.  The first whistleblower reported their concerns internally prior to notifying the SEC. This information contributed significantly to an existing investigation. The SEC was not previously aware of this misconduct. This whistleblower’s information assisted the staff in developing a well-organized and effective investigation leading to the enforcement action.  The whistleblower kept in touch with the staff throughout the investigation to help uncover the full extent of misconduct as well as identify all possible witnesses. This information as well as other assistance also helped the SEC staff to obtain evidence of wrongdoing that was occurring overseas. Without this information from the whistleblower, the activity would have been difficult to uncover. In this case, the first whistleblower received an award of $2.6 million.The Securities and Exchange Commission has kept busy, even through the holidays. On January 10th, 2022, the SEC put out a press release announcing that three more people have received bounties after working with SEC staff to identify and discontinue wrongdoing in the financial sector. Continue reading

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