And Yet Another Round of SEC Whistleblower Awards

By the Constantine Cannon Whistleblower Team
It was just two weeks ago that we reported that the Securities and Exchange Commission (SEC) made a round of awards in June under the SEC Whistleblower Program, including a rather hefty $20 million award. As we noted, that round followed a steady stream of SEC whistleblower payouts over the past year — six awards on April 7 and 8; five awards on September 29 and 30; another five awards between August 28 and September 4; and three awards on July 16.
What Were the Recent SEC Whistleblower Awards?
Well, the SEC did not wait very long to issue yet another round of awards, this time comprising roughly 10 awards between June 30 and July 8: (i) a $3.5 million award on July 8,[1] (ii) a $168,000 award on July 8,[2] (iii) a $1 million award on July 7,[3] (iv) a $1 million award on July 2,[4] (v) joint awards totaling $1.4 million on July 2,[5] (vi) joint awards totaling $2 million on July 1,[6] and (vii) several de minimis joint awards on June 30.[7]
Per its practice of strictly protecting the identity of its whistleblowers, the SEC provided no information on the whistleblowers, the information they provided, the subject of the SEC’s enforcement action, or the misconduct involved. But there were a few notable takeaways from the agency’s heavily redacted Award Determination Orders.
First, several of the recent awards departed from the amount the SEC Claims Review Staff had originally recommended in its preliminary award determination. The SEC rarely deviates from the preliminary determination unless it is based on the whistleblower’s formal objections to the preliminary award. There is no indication that was the case here. It appears the SEC just changed its mind. Whether this presents a new direction the SEC may be heading in its awards review process remains to be seen. If so, it raises serious questions about the ability of a whistleblower to challenge the amount of any award given the current system is set up to allow that challenge only at the preliminary award phase.
Second, several of the recent awards were lower than they otherwise would have been because of what the SEC considered was the “unreasonable delay” of the whistleblower in reporting to the agency. This has been a common practice with the agency, especially in more recent years, with the agency stressing the need for whistleblowers to report misconduct promptly. Typically, the delay the SEC has acted on is more than a year as the agency encourages whistleblowers to report their concerns internally and try to work them through with the company before reporting to the agency. Nevertheless, whistleblowers and their counsel should be mindful of the timing of their approach to the agency to ensure they are acting with appropriate urgency, especially when any unreasonable delay could harm investors or the public more broadly.
Third, several of the recent awards were substantially lowered because of the SEC’s finding that the whistleblowers participated in and/or benefitted from the underlying misconduct. While the SEC rules do not necessarily bar wrongdoers from being whistleblowers, they are clear that any award determination can and likely will be impacted. And that has been the SEC’s general practice for years. So the whistleblower’s culpability is definitely a factor to consider in deciding whether to move forward under the program, though there often are other good reasons for fraudsters to voluntarily report to the agency outside of any potential award, including mitigating any criminal or civil exposure for stepping forward.
Will the Flow of SEC Whistleblower Awards Continue?
As we previously reported, Constantine Cannon whistleblower partner Gordon Schnell looks to this continued string of SEC awards as a strong indication the agency stands firmly behind its whistleblower program. This latest round of awards, following so closely on the heels of the June awards, just reinforces that view. Schnell expects the awards will continue apace.
As to the small size of the recent awards, Schnell is not concerned. “While the recent awards were relatively small,” Schnell says, “the SEC has recently issued significantly sizeable awards showing a willingness to go big when the circumstances warrant it.” This includes a $20 million whistleblower payout in June and a $53 million payout in April. Schnell is optimistic this flow of SEC whistleblower awards will continue, with more large awards to follow in the coming months.
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.
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[1] See https://www.sec.gov/files/owb-2026-39.pdf.
[2] See https://www.sec.gov/files/owb-2026-38.pdf.
[3] See https://www.sec.gov/files/final-order-2026-37.pdf.
[4] See https://www.sec.gov/files/final-order-2026-36.pdf.
[5] See https://www.sec.gov/files/final-order-2026-34.pdf.
[6] See https://www.sec.gov/files/final-order-2026-33.pdf.
[7] See https://www.sec.gov/files/final-order-2026-32.pdf.
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