SEC Issues Three Orders Granting a Total of $7.5 Million in Whistleblower Awards

Posted July 22, 2025

By the Constantine Cannon Whistleblower Team

On July 16, 2025, the SEC published three new orders determining whistleblower awards. Per the SEC’s usual practice, the orders are heavily redacted to protect, among other things, the confidentiality of the whistleblowers who provided the tips to the SEC. Nevertheless, a few important takeaways can be found by reading through the (redacted) lines.

1. SEC Awards Two Joint Whistleblowers $5.4 Million

In the first of the three July 16 Orders, the SEC adopted the preliminary determination of the Claims Review Staff (“CRS”) to award $5.4 million to two joint whistleblowers who voluntarily provided original information to the SEC that led to a successful enforcement action.[1]

We recently addressed the benefits and risks of joint whistleblowers working together, and this SEC order and award serves as another example of how that can work. Here, the SEC treated the two claimants as “joint whistleblowers” because they “presented themselves as acting jointly” in their Form TCRs (the SEC form to submit tips, complaints, or referrals) and Forms WB-App (the SEC form to submit applications for whistleblower awards under the SEC whistleblower program).

As to the amount of the award, which can range from 10% to 30%, the SEC considers: “(1) the significance of information provided to the [SEC]; (2) the assistance provided in the [SEC] action; (3) 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.”[2] Here, the SEC found that the $5.4 million award to the two joint whistleblowers was appropriate given that (i) their “information contributed to the [SEC] staff’s decision to open an investigation” into the company; (ii) they “produced the key document that formed the basis of the [SEC’s] findings in the Covered Action”; (iii) they “provided ongoing assistance to staff”; and (iv) they “were instrumental in assisting the staff in obtaining additional relevant documents from the Company.”[3]

2. SEC Awards Whistleblower $1.3 Million

In the second July 16 Order, the SEC adopted the preliminary determination of the CRS to award roughly $1.3 million to a single whistleblower claimant who voluntarily provided original information to the SEC that led to a successful enforcement action.[4] In this case, the SEC emphasized that the whistleblower “provided significant information alerting [SEC] Enforcement staff to the potential violations prompting the opening of the investigation, and thereafter provided helpful assistance, including communicating with [SEC] staff and providing documentation supporting Claimant’s information.”[5]

3. SEC Awards Two Whistleblowers $400,000 Each

In the final July 16 Order, the SEC adopted the preliminary determination of the CRS recommending that the SEC (i) “waive the TCR filing requirements under Exchange Act Rule 21F-9(b)” as to Claimant 1; (ii) award Claimant 1 over $400,000; and (iii) award Claimant 2 over $400,000.[6]

According to the Order, Claimant 1 apparently submitted the Form TCR form through the SEC’s online portal, but “did not submit the whistleblower declaration as required under Rule 21F-9(b),”[7] which requires a declaration under penalty of perjury at the time the whistleblower submission is made that the information is “true and correct to the best of your knowledge and belief.”[8] Nevertheless, the SEC exercised its discretionary authority under Exchange Act Section 36(a) to waive the failure to comply with Rule 21F-9(b) (i) because the whistleblower voluntarily provided original information to the SEC that led to the a successful enforcement action; (ii) in light of the way Claimant 1 submitted the TCR on the portal, “Claimant 1 was not prompted by the TCR System to provide the requisite declaration under penalty of perjury”; (iii) SEC “Enforcement staff interviewed Claimant 1 twice and were able to assess the credibility of Claimant 1’s tip”; and (iv) “Claimant 1 voluntarily helped alert staff to the misconduct and then provided ongoing assistance that resulted in the Covered Action.”[9]

In determining the amount of the awards for Claimant 1 and Claimant 2, the SEC awarded less than the 30% presumption that can apply where the total award is $5 million or less,[10] because the SEC found an “unreasonable reporting delay,” insofar as Claimant 1 and Claimant 2 “waited to report to the [SEC] for 20 and 23 months, respectively.”

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These three SEC orders awarding millions of dollars to the whistleblowers are certainly welcome news. Whistleblowers often take risks when reporting misconduct to the authorities and they deserve to be rewarded for their efforts. We hope this will be a sign of more awards to come from the SEC in the future.

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