SEC Annual Whistleblower Report Confirms Drop Off In Whistleblower Awards

By the Constantine Cannon Whistleblower Team
Last month (February 11), the Securities and Exchange Commission (SEC) issued its Annual Whistleblower Report to Congress where it details the highlights of the SEC Whistleblower Program for the most recent year.[1] Unfortunately, there was not all that much to report given the drop off in SEC whistleblower awards and activity for 2025. That may explain why the agency made almost no effort to promote the report or the whistleblower results for the year.
How Did the Total Amount of SEC Whistleblower Awards for 2025 Compare to Prior Years?
Perhaps the most telling feature of how the program fared last year was the $60 million in total awards, which was far lower than what the SEC doled out to whistleblowers over the past several years — $255 million in 2024, $600 million in 2023, $229 million in 2022, $175 million in 2020, and $168 million in 2018.
To be fair, the $60 million in awards this past year is roughly the same as what the SEC awarded in 2019, and more than what the SEC awarded in any year prior to 2018. But it was not just the lower annual haul of awards that marked a significant departure for the SEC Whistleblower Program compared to the last few years. It was also what appears to be a not-so-subtle shift in tone the agency has taken towards the program.
Has the SEC Stopped Promoting Its Whistleblower Program?
Most notably has been the lack of any press releases promoting the program. Up until this past year, the SEC issued a press release with every whistleblower award it made, trumpeting the award, the whistleblower’s contribution, and the importance of the whistleblower program more broadly. The press releases would typically quote the head of the SEC Whistleblower Office, the head of SEC enforcement, and sometimes even the SEC Chairperson on the critical role of whistleblowers, encouraging them to come forward with the promise of hefty awards.
The SEC had promoted the whistleblower program in other ways too, in speeches and other news releases, underscoring the value of the program and the whistleblowers it brings forward and marking particular highpoints of the program. For example, the agency engaged in a big PR splash when it crossed the $1 billion mark in whistleblower awards in September 2021, with SEC Chair Gary Gensler himself playing a prominent role in the campaign.[2]
This whistleblower promotional activity all but disappeared last year. Not even last month’s Annual Whistleblower Report was given any meaningful airtime. It is buried on the agency’s website.[3] And within the report, there is nary a mention of the valuable role of whistleblowers and the agency’s support for the program.
The closest the SEC comes to promoting the program is its statement that “the Program continues to support the work” of the agency and “helps to protect Main Street investors when whistleblowers submit information to the SEC about potential securities violations.” Other than that, the report says very little about what the whistleblower program accomplished this past year and devotes as much attention to the awards it made as to the reasons why it denied so many awards.
Does the SEC Still Support Its Whistleblower Program?
Constantine Cannon whistleblower partner Gordon Schnell — who has written and been quoted extensively on the current state of the SEC Whistleblower Program — believes the Annual Report is consistent with where the SEC currently is with the program. “I believe the SEC still strongly supports the whistleblower program,” Schnell says, “but is reining in the program in terms of its promotion and awards.”
Schnell sees the agency taking a more rigid approach as to what qualifies for an award and on the size of any awards. But he believes this is a temporary trend and that the agency will soon return to strongly promoting the program and issuing the sizeable awards that had been a hallmark of the program over the past few years. According to Schnell, “The SEC recognizes the value of its whistleblowers and will do what is necessary to maintain the flow of vital information they provide.”
Schnell notes it may take some time for the SEC to get there as its more stingy approach to issuing whistleblower awards has continued into this new fiscal year, with the SEC issuing only one whistleblower award order in the last five months (on February 26).[4] And that single order only amounted to $570,000 shared among multiple whistleblowers. Even more strikingly, Schnell remarks that the recent award followed a string of more than thirty SEC orders denying any whistleblower award at all.[5]
Will There Be An Increase in the Amount of SEC Whistleblower Awards?
But Schnell is confident more sizeable awards are on the horizon. “After a year of fairly significant disruption and major changes in leadership and enforcement direction, the SEC finally seems to be getting its footing again.”
Schnell expects that “with this rebalancing of the agency and its priorities will come a renewed recognition of how invaluable whistleblowers are to SEC enforcement and how the whistleblower awards program is the engine that drives whistleblowers forward.” So words to the wise for would-be SEC whistleblowers according to Schnell, “Keep those tips coming; the SEC still very much wants to hear from you.”
Constantine Cannon Has Substantial Experience Representing SEC Whistleblowers
Constantine Cannon has substantial experience and success representing SEC whistleblowers. So if you think you might have information on potential securities violations, or would like to learn more about the SEC Whistleblower Program, or what it means to be a whistleblower more broadly, please do not hesitate to contact us. We will connect you with an experienced member of the Constantine Cannon whistleblower team for a free and confidential consultation.
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Sources:
[1] See https://www.sec.gov/files/fy25-annual-whistleblower-report.pdf.
[2] See https://www.sec.gov/newsroom/press-releases/2021-177 (SEC press release); https://www.youtube.com/watch?v=kgwqO5GrDZY (SEC video).
[3] See https://www.sec.gov/enforcement-litigation/whistleblower-program.
[4] See https://www.sec.gov/files/34-104896.pdf.
[5] See https://www.sec.gov/enforcement-litigation/whistleblower-program/final-orders-whistleblower-award-determinations.
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