SEC Makes Another Round of Whistleblower Awards, Including a Whopping $53M Award

Posted April 22, 2026

By the Constantine Cannon Whistleblower Team

On April 7 and 8, the Securities and Exchange Commission (SEC) made six awards under the SEC Whistleblower Program, which rewards whistleblowers with up to 30% of the Government’s recovery for enforcement actions based on information the whistleblowers provide. It is just the latest round in a series of whistleblower awards the SEC has made over the past year — five on September 29-30, another five between August 28 and September 4, and three on July 16.

How Large Were the Recent SEC Whistleblower Awards?

This latest wave of awards consisted of the following:

- A $53 million award to a whistleblower who: (i) “provided significant information early in the Commission staff’s investigation that demonstrated the scope and severity of violations occurring at the Company and that its senior management was aware of the these violations,” (ii) “provided extensive ongoing assistance throughout the course of the investigation, participating in numerous meetings with the staff and providing sworn testimony,” and (iii) “internally reported his/her concerns directly to senior management.” However, the SEC noted the size of the award was negatively impacted by the whistleblower’s substantial delay in reporting to the agency, especially because he/she was a senior employee who received confirmation of the wrongdoing.[1]

- A $300,000 award to a whistleblower who “provided significant information, alerting Enforcement staff to the underlying misconduct, communicated with staff numerous times, provided substantial additional assistance and documents, and reported the concerns internally.” However, the SEC noted the size of the award was negatively impacted by the whistleblower’s participation in the misconduct and their unreasonable delay in reporting the misconduct to the agency (33 months).[2]

- A $500,000 award to a whistleblower who “provided significant and detailed information prompting the opening of the investigation, participated in multiple interviews with Commission staff, gave documentary evidence, identified witnesses, and provided a roadmap for the investigatory staff.” The SEC did not identify any factors the negatively impacted the award.[3]

- A $500,000 award to a whistleblower who “provided information that alerted Commission staff to the underlying conduct, prompting the opening of the investigation, and thereafter provided substantial information and continuing assistance, including through communicating with Commission staff on numerous occasions, which helped advance and expedite the Covered Action investigation.” The SEC did not identify any factors that negatively impacted the award.[4]

- A $500,000 award to a whistleblower who “reported his/her concerns internally, . . . [which] caused the company to report the conduct to Commission staff, prompting the opening of the staff’s investigation.” The SEC pointed to SEC Rule 21F-4(c)(3), which gives “credit” to the whistleblower who reports internally, prompting the company to report to the SEC, as long as the whistleblower reports to the SEC within 120 days of reporting internally. In this instance, the SEC noted the whistleblower also provided additional critical information to the staff during its investigation. The SEC did not identify any factors that negatively impacted the award.[5]

- An award of an undisclosed amount to a whistleblower who provided significant ongoing assistance to the SEC relating to an open investigation, which saved agency staff significant time and resources. The SEC did not identify any factors that negatively impacted the award.[6]

As is standard practice with its Whistleblower Award Orders, the SEC provides little additional detail about the whistleblower or the underlying enforcement action to protect the confidentiality of the whistleblower. In fact, the SEC redacts from its Orders any information that might give even a whiff of who the whistleblower is, the company involved, and the misconduct at issue.

What Was Notable About the SEC’s Latest Round of Whistleblower Awards?

There are several notable features in this most recent bundle of awards.

First, the $53 million award is the largest SEC whistleblower award in almost two years, one of the highest awards ever made under the program, and perhaps most importantly, follows an extended period of relatively paltry awards. Indeed, this single award is almost as much as the $60 million in total awards the SEC doled out last year, which as reflected in the SEC’s most recent Annual Whistleblower Report, was indicative of significant drop off in SEC whistleblower awards.

But as large as the $53 million award is, it apparently was supposed to be significantly larger. In the SEC’s Preliminary Determination, it found the whistleblower was entitled to the $53 million plus a percentage of the Government’s recovery in a related action brought by another agency. This follows from SEC Rule 21F-3(b), which provides for whistleblowers to receive awards based on the Government’s recovery in related agency enforcement actions based on the information the whistleblower reported to the SEC.

However, in a so-called Superseding Preliminary Determination, the SEC reversed itself on this additional award — which may have amounted to tens of millions of dollars — finding there was no clear way to calculate the amount of the Government’s recovery in that related action. In other words, rather than engage in a good-faith estimate of the amount of the related recovery (like what the SEC originally did), the SEC decided to give the whistleblower no credit at all.

Many see that agency’s decision here as an overly rigid and technical reading of the whistleblower award rules, and even worse, a further indication the current SEC is applying a more stingy approach to making whistleblower awards. It has not escaped notice that the SEC’s Superseding Preliminary Determination reversed the agency’s earlier award made under the prior Administration. Indeed, in contesting the award determination, the whistleblower argued that “the real motivation in issuing the Superseding Preliminary Determination was the change in federal administration and new agency leadership.”

Second, with these recent awards, the SEC doubled down on the need for SEC whistleblowers to act without delay in reporting potential violations to the agency. In two of these awards, the SEC underscored this need by noting its award determinations were impacted by what it considered the whistleblowers’ unreasonable delay in approaching the agency.

Third, the SEC reinforced what it sees as the importance of whistleblowers reporting their concerns internally to give the company an opportunity to address the alleged wrongdoing in-house. It is a factor the agency repeatedly points to in its award calculation decisions. And as the SEC highlighted with one of its recent awards, under SEC Rule 21F-4(c)(3), a whistleblower who reports internally can get credit for the company itself reporting to the agency. Of course, reporting internally should always be weighed against the risk the company will retaliate against the whistleblower for doing so. It is a very case specific and company specific decision for whistleblowers.

According to Constantine Cannon whistleblower partner Gordon Schnell, “Most of our clients come to us only after they have reported their concerns internally and the company has retaliated against them.” Schnell says, “These are loyal employees, dedicated to their company, trying to address what they see as serious misconduct that needs to be addressed, only to be ignored, silenced, or removed from their position altogether.” Schnell advises his clients to tread very carefully in this area.

In terms of the recent spate of awards, Schnell is pleased to see the SEC continuing to embrace its Whistleblower Program. He is especially happy to see the agency still has an appetite to issue large awards (though its use of a Superseding Preliminary Order to reverse an earlier award decision does give him pause). All in, Schnell sees “the spate of SEC whistleblower awards continuing, with more big awards to come.”

Constantine Cannon Has Substantial Experience Representing SEC Whistleblowers

Constantine Cannon has substantial experience representing SEC whistleblowers. If you would like to learn more about the SEC Whistleblower Program, our work representing whistleblowers under the program, our long list of whistleblower successes, 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.

Sources:

[1] See https://www.sec.gov/files/final-order-04072026.pdf.

[2] See https://www.sec.gov/files/final-order-04072026-2.pdf.

[3] See https://www.sec.gov/files/2026-11.pdf.

[4] See https://www.sec.gov/files/2026-12.pdf.

[5] See https://www.sec.gov/files/2026-13.pdf.

[6] See https://www.sec.gov/files/2026-14.pdf.

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