ARTICLE
2 September 2021

SEC Awards Nearly $2.6 Million To Five Whistleblowers

CW
Cadwalader, Wickersham & Taft LLP

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Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
The SEC awarded approximately $2.6 million to five whistleblowers who provided valuable information or independent analysis in three separate enforcement proceedings.
United States Corporate/Commercial Law
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The SEC awarded approximately $2.6 million to five whistleblowers who provided valuable information or independent analysis in three separate enforcement proceedings.

In the first action, the SEC awarded a whistleblower approximately $1.2 million for an independent analysis that was based on the whistleblower's own complex algorithm and that used public data. The SEC stated that the independent analysis saved SEC staff time and resources during settlement negotiations for the enforcement action.

In the second action, SEC awarded over $1 million to three whistleblowers, all of whom held compliance roles, for providing information that led to a successful enforcement action. The SEC stated that the whistleblowers were eligible for the award, notwithstanding their positions at the company, because the information was submitted to the SEC more than 120 days following the initial internal complaint.

In the third action, the SEC awarded more than $350,000 to a whistleblower who, by means of "unusual effort and expertise developed over many years," provided information regarding a microcap company's stock in connection with a suspicious promotional campaign. The SEC stated that the whistleblower identified patterns among publicly available information that allowed the SEC to target and prevent misconduct while preserving assets.

Primary Sources

  1. SEC Press Release: SEC Issues Whistleblower Awards Totaling $2.6 Million
  2. SEC Order Determining Whistleblower Award Claim: File No. 2021-85
  3. SEC Order Determining Whistleblower Award Claim: File No. 2021-86
  4. SEC Order Determining Whistleblower Award Claim: File No. 2021-87

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