The U.S. Commodity Futures Trading Commission (CFTC) recently issued its annual report to Congress on its whistleblower program, announcing that enforcement actions associated with the program have resulted in monetary sanctions totaling over $3.2 billion since the Commission issued its first award in 2014. Since the whistleblower program began, the CFTC has issued 55 orders granting over $390 million in award payments to whistleblowers.
There are several key takeaways from the report. In fiscal year 2025, the Commission granted three whistleblower award applications totaling $4.6 million in award payments. The two enforcement actions associated with these whistleblower tips resulted in monetary sanctions of about $16 million. Although that amount was down from the prior year’s report when the Commission recovered approximately $162 million in monetary penalties assessed in 12 enforcement actions associated with whistleblower tips, the report indicates that the program shows progress for the future. According to the Report, as of the end of fiscal year 2025, the CFTC recorded liabilities for pending payments to whistleblowers of approximately $400 million and total future payments to whistleblowers ranging from $0 to nearly $998 million, depending on whether the whistleblowers are determined to be eligible for an award and the related sanctions are collected. Note 1A
The report also reflects robust engagement with the program. The Commission received 1,697 TRCs (Tip, Complaint, or Referral) submissions in fiscal year 2025, and received 203 reward applications (WB-APPs). The CFTC also issued 120 denials to claimants who submitted applications that failed to meet the law’s requirements.
Finally, the report indicates the types of whistleblower reports that are submitted to the program as well as the geographic origin of the tips. According to the report, the most common whistleblower tips include fraudulent representations of investment returns and customers’ inability to withdraw funds after investing, registration and recordkeeping violations, and disruptive trading, such as spoofing and market manipulation. Most of the whistleblower complaints came from the US, Canada, and the United Kingdom.
Phillips & Cohen has been instrumental in securing CFTC whistleblower rewards for clients, including an award of over $4 million to a Phillips & Cohen whistleblower in August 2024.
Phillips & Cohen is the most successful law firm representing whistleblowers, with recoveries from cases totaling over $13 billion and winning 26 awards for clients under Dodd-Frank whistleblower reward programs. P&C’s roster includes the former Director of the Whistleblower Office of the CFTC, Christopher Ehrman, the former first head of the SEC Office of the Whistleblower, Sean McKessy, the attorney with the most awards under the Dodd-Frank whistleblower awards programs, Erika Kelton, and numerous attorneys with decades of experience representing financial fraud whistleblowers.