Developments in Securities Regulation, Corporate Governance, Capital Markets, M&A and Other Topics of Interest. MORE

In its 2014 Report to Congress on the Dodd-Frank Whistleblower Program, the SEC described the profile of successful whistleblowers. Because the SEC must keep the identity of whistleblowers confidential, it can only describe certain commonalities which included:

  • The information provided by each award recipient was specific, in that the whistleblower identified particular individuals involved in the fraud, or pointed to specific documents that substantiated their allegations or explained where such documents could be located.
  • The alleged misconduct was relatively current or ongoing. Because of the specific, credible, and timely nature of their tips, their information was forwarded to Enforcement staff, who followed up by contacting the whistleblowers. These whistleblowers then provided additional information or assistance to the staff during the course of the investigation.
  • Over 40% of the individuals who received awards were current or former company employees. Furthermore, an additional 20% of the award recipients were contractors, consultants, or were solicited to act as consultants for the company committing the securities violation.
  • Of the award recipients who were current or former employees, over 80% raised their concerns internally to their supervisors or compliance personnel before reporting their information of wrongdoing to the Commission.
  • If represented by counsel, a whistleblower may choose to submit his or her tip anonymously to the Commission. However, only one of the fourteen award recipients to date submitted the information anonymously.

Other Interesting information in the report includes:

  • The SEC received 3,620 whistleblower tips in 2014, compared to 3,238 in 2013.
  • Consistent with prior years, the most common allegations are corporate disclosures and financials, offering fraud, and manipulation (excluding the category of “other”).
  • Domestically most tips come from California, and internationally from India and the United Kingdom.


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