2021 was a year of large whistleblower awards. Many of these came from the SEC Whistleblower Program. The CFTC Whistleblower Program also awarded substantial rewards to whistleblowers. The following is a list of the top three biggest whistleblower rewards for 2021:
- CFTC Whistleblower award of $200 million – The CFTC awarded almost $200 million to a single whistleblower whose identity remains undisclosed. The whistleblower came forward with information on the manipulation of financial benchmarks ultimately used by banks. These benchmarks have various uses, including being referenced for the basis pricing of financial instruments, such as options and swaps traded on commodity exchanges. The whistleblower provided information that led the CFTC, another U.S. regulator, and a foreign regulator to investigate these practices. Although not formally disclosed, it is believed that the entity manipulating these benchmarks was Deutsche Bank.
- SEC Whistleblower award of $110 million – A whistleblower was awarded $110 million, the second-highest amount awarded by the SEC Whistleblower Program. The whistleblower’s identity is unknown, as is the entity subject of the enforcement action. The SEC did indicate that the whistleblower provided information gleaned from their independent analysis. It is understood that the whistleblower was an outsider who analyzed publicly available information to uncover the misconduct. A second whistleblower in this case received $4 million.
- SEC Whistleblower award of $50 million – Two whistleblowers were awarded $50 million, making it the third-largest award under this program. Regarding the enforcement action, disclosed information was sparse. The SEC did indicate that the whistleblowers brought forward information on a fraudulent scheme involving complex transactions which harmed investors.