December 14, 2017
Authored by: Jennifer Mammen, Mark Srere, Elaine Koch and Jennifer Berhorst
In the course of one week, the United States Securities and Exchange Commission announced awards to three whistleblowers totaling more than $20 million under the Dodd-Frank Whistleblower Program.
On November 30, the SEC announced awards of more than $8 million each to two whistleblowers. The first individual alerted the agency to conduct that became the subject of an enforcement action and continued to provide additional information throughout the investigation, while the second whistleblower provided information that allowed the agency to understand and asses the implications of the misconduct. Under the Whistleblower Program, eligible whistleblowers may receive awards of between 10% and 30% of the sanctions collected in actions brought by the SEC and related actions brought by other authorities. To maintain the confidentiality of the individual whistleblower, the SEC does not release information regarding the target of the investigation or the percentages of awards granted to the whistleblowers, but in the Notice of Covered Action it did note that in cases in which more than one whistleblower receives an award, the combined awards cannot exceed 30% of the recovery. Seven other individuals submitted unsuccessful applications for whistleblower awards related to that enforcement.
Less than one week later, the SEC announced an award of more than $4.1 million to a foreign national working outside of the United State who reported information regarding a multi-year, widespread securities violation. In announcing the award, Jane Norberg, Chief of the SEC’s Office of the Whistleblower noted that the whistleblower was a former company insider and