In the Matter of the Claims for an Award
The SEC awarded over $1 million in total whistleblower payments to three compliance employees—Claimant 1 (largest share for vital, comprehensive info and extraordinary assistance), Claimant 2 (second largest for being first to report and framing the case), and Claimant 3 (smallest share for helpful but less critical info)—all eligible under the 120-day internal reporting exception after waiting over 120 days to disclose misconduct to the Commission.
The SEC awarded over $1 million collectively to three whistleblowers—Claimants 1, 2, and 3—who provided original information leading to a successful enforcement action, though the underlying fraud and respondent remain redacted. Claimant 1 received the largest award for providing the most comprehensive and vital information, along with extraordinary investigative assistance; Claimant 2 received a substantial award as the first to report, establishing the investigation’s framework and offering ongoing support; Claimant 3 received a smaller award for timely internal reporting followed by external disclosure after 120 days, with information deemed less pivotal. All three were compliance employees who qualified under Rule 21F-4(b)’s 120-day exception, and no party contested the preliminary determinations.
The SEC awarded over $1 million in total whistleblower payments to three individuals—Claimants 1, 2, and 3—who provided original information leading to a successful enforcement action, though the specific nature of the fraud and the entity involved were redacted. Claimant 1 received the largest share of the award for supplying the most comprehensive and vital information, as well as providing extraordinary assistance throughout the investigation, which proved essential to its success. Claimant 2, who was the first to report to the SEC, received a substantial award for initiating the framework of the case and offering continuous cooperation, enabling staff to develop targeted information requests. Claimant 3, while helpful, received a smaller award because their information was less central to the outcome, though they still qualified under Rule 21F-4(b) by reporting internally first and then contacting the SEC more than 120 days later, after learning senior management was already aware of the misconduct. All three claimants held compliance roles, but their eligibility was preserved due to the 120-day exception, which allows compliance personnel to qualify if they delay reporting to the SEC beyond that period. The Claims Review Staff’s preliminary recommendations were not contested by any claimant, leading the SEC to adopt them as final. The awards reflect the Commission’s prioritization of timely, impactful, and cooperative disclosures, even from insiders with compliance responsibilities.
Extracted insights
- $1.00M $1 million $1M–$10M
- person extraordinary assistance during investigation
- agency potential securities violations to sec
- agency sec leading to successful enforcement of covered action
- agency sec over 120 days after receiving information
- agency Securities and Exchange Commission
- person whistleblower awards
- Claimant 1 receive whistleblower award Percentage of monetary sanctions in Covered Action
- Claimant 2 receive whistleblower award Percentage of monetary sanctions in Covered Action
- Claimant 3 receive whistleblower award Percentage of monetary sanctions in Covered Action
- Claimants 1, 2, and 3 provided original information SEC leading to successful enforcement of Covered Action
- Claimant 1 provided Most significant and comprehensive information about conduct
- Claimant 1 provided Extraordinary assistance during investigation
- Claimant 2 was first to report Potential securities violations to SEC
- Claimant 2 provided Framework for developing information requests
- Claimant 3 reported potential violations SEC over 120 days after receiving information
- Whistleblower awards will collectively result in payment Over $1 million
- SEC issued Order Determining Whistleblower Award Claims on August 27, 2021
UNITED STATES OF AMERICA Before the SECURITIES AND EXCHANGE COMMISSION SECURITIES EXCHANGE ACT OF 1934 Release No. 92778 /August 27, 2021 WHISTLEBLOWER AWARD PROCEEDING File No. 2021-86 In the Matter of the Claims for an Award in connection with Notice of Covered Action ORDER DETERMINING WHISTLEBLOWER AWARD CLAIMS The Claims Review Staff (“CRS”) issued Preliminary Determinations recommending that (“Claimant 1”) receive a whistleblower award of percent ( %) of monetary sanctions collected or to be collected in the above-referenced Covered Action, (“Claimant 2”) receive a whistleblower award of percent ( %) of monetary sanctions collected or to be collected in the Covered Action, and (“Claimant 3”) receive a whistleblower award of percent ( %) of monetary sanctions collected or to be collected in the Covered Action. The awards will collectively result in payment of over $1 million. Claimants 1, 2, and 3 did not contest the Preliminary Determinations. 1 The recommendations of the CRS are adopted. The record demonstrates that Claimants 1, 2, and 3 each voluntarily provided original information to the Commission that led to the successful enforcement of the Covered Action. 2 In determining that Claimant 1 should receive an award of % of monetary sanctions collected or to be collected in the Covered Action, we considered that Claimant 1 provided the most significant and comprehensive information about the conduct to staff that proved vital to the success of the Covered Action. Claimant 1 also provided extraordinary assistance during the course of the investigation. In determining that Claimant 2 should receive an award of % of monetary sanctions collected or to be collected in the Covered Action, we considered that Claimant 2 was the first claimant to report to the Commission, and Claimant 2’s information provided a framework for developing information requests. Claimant 2 also provided continuing assistance. In determining that Claimant 3 should receive an award of % of monetary sanctions collected or to be collected in the Covered Action, we considered that while helpful, Claimant 3’s information was not as significant to the overall success of the Covered Action as the information submitted by Claimants 1 and 2. Claimant 3 also provided continuing assistance. Accordingly, it is hereby ORDERED that Claimant 1 shall receive an award of percent ( %) of monetary sanctions collected or to be collected in the Covered Action, Claimant 2 shall receive an award of percent ( %) of monetary sanctions collected or to be collected in the Covered Action, and Claimant 3 shall receive an award of percent ( %) of monetary sanctions collected or to be collected in the Covered Action. By the Commission. Vanessa A. Countryman Secretary
UNITED STATES OF AMERICA Before the SECURITIES AND EXCHANGE COMMISSION SECURITIES EXCHANGE ACT OF 1934 Release No. 92778 /August 27, 2021 WHISTLEBLOWER AWARD PROCEEDING File No. 2021-86 In the Matter of the Claims for an Award in connection with Notice of Covered Action ORDER DETERMINING WHISTLEBLOWER AWARD CLAIMS The Claims Review Staff (“CRS”) issued Preliminary Determinations recommending that (“Claimant 1”) receive a whistleblower award of percent ( %) of monetary sanctions collected or to be collected in the above-referenced Covered Action, (“Claimant 2”) receive a whistleblower award of percent ( %) of monetary sanctions collected or to be collected in the Covered Action, and (“Claimant 3”) receive a whistleblower award of percent ( %) of monetary sanctions collected or to be collected in the Covered Action. The awards will collectively result in payment of over $1 million. Claimants 1, 2, and 3 did not contest the Preliminary Determinations. 1 The recommendations of the CRS are adopted. The record demonstrates that Claimants 1, 2, and 3 each voluntarily provided original information to the Commission that led to the successful enforcement of the Covered Action. 2 In determining that Claimant 1 should receive an award of % of monetary sanctions collected or to be collected in the Covered Action, we considered that Claimant 1 provided the most significant and comprehensive information about the conduct to staff that proved vital to the success of the Covered Action. Claimant 1 also provided extraordinary assistance during the course of the investigation. In determining that Claimant 2 should receive an award of % of monetary sanctions collected or to be collected in the Covered Action, we considered that Claimant 2 was the first claimant to report to the Commission, and Claimant 2’s information provided a framework for developing information requests. Claimant 2 also provided continuing assistance. In determining that Claimant 3 should receive an award of % of monetary sanctions collected or to be collected in the Covered Action, we considered that while helpful, Claimant 3’s information was not as significant to the overall success of the Covered Action as the information submitted by Claimants 1 and 2. Claimant 3 also provided continuing assistance. Accordingly, it is hereby ORDERED that Claimant 1 shall receive an award of percent ( %) of monetary sanctions collected or to be collected in the Covered Action, Claimant 2 shall receive an award of percent ( %) of monetary sanctions collected or to be collected in the Covered Action, and Claimant 3 shall receive an award of percent ( %) of monetary sanctions collected or to be collected in the Covered Action. By the Commission. Vanessa A. Countryman Secretary