DODD-FRANK SECTION 21F INTELLIGENCE
SEC Whistleblower Bounty Tracker
Public award orders, financial sanction recoveries, and historical internal audit tipsters who exposed material financial reporting fraud.
KEY FACTS
- Under Section 21F of the Securities Exchange Act (Dodd-Frank), whistleblowers are eligible for 10% to 30% of monetary sanctions collected.
- The SEC Office of the Whistleblower has awarded over $525.0M across highlighted accounting and disclosure fraud enforcement cases.
- Whistleblower identities and identifying details are strictly protected from public disclosure under federal statutory confidentiality rules.
Highlighted Awards Total
$525.0M
Record Single Bounty
$279.0M
Statutory Bounty Range
10% to 30%
Sanction Threshold
> $1,000,000
SEC Accounting Fraud Award Orders
Office of the Whistleblower| Order Date | Release Number | Enforcement Matter | Insider Category | Award Amount | SEC Release |
|---|---|---|---|---|---|
| May 5, 2023 | 34-97435 | International Bribery & Books-and-Records Fraud The largest single whistleblower award in SEC history. The whistleblower provided critical initial documentation exposing extensive books-and-records falsification and corrupt third-party agent payments. | Former Company Insider | $279.0M | View Order ↗ |
| October 22, 2020 | 34-90247 | Systematic Revenue Timing and Channel Stuffing Whistleblower provided persistent internal communications showing executives knowingly authorized concessions, side agreements, and extended payment terms while recognizing immediate revenue. | Internal Sales Executive | $114.0M | View Order ↗ |
| March 19, 2018 | 34-82901 | Off-Balance Sheet Liabilities & Loan-Loss Under-Provisioning Two individuals shared an award for alerting regulators to hidden asset impairment and debt covenant breaches concealed through complex structured financing vehicles. | Joint Internal Audit & Risk Officers | $50.0M | View Order ↗ |
| September 15, 2021 | 34-92994 | Foreign Subsidiary Accounting & Revenue Round-Tripping Whistleblower deciphered complex circular transactions across foreign subsidiaries that fabricated trading volume and reciprocal commission streams. | Operations Specialist | $36.0M | View Order ↗ |
| May 19, 2022 | 34-94947 | Improper Capitalization of Software and Research Expenses Alerted the Division of Enforcement to software engineering overhead improperly capitalized as balance sheet intangible assets rather than charged to period operating expense. | Financial Systems Analyst | $28.0M | View Order ↗ |
| August 4, 2023 | 34-98061 | Cookie Jar Reserve Releases and Bonus Smoothing Provided audit workpapers indicating general litigation and inventory reserves were systematically drawn down at year-end to meet consensus Wall Street earnings forecasts. | Accounting Department Staff | $18.0M | View Order ↗ |
HISTORIC WHISTLEBLOWER DOSSIERS
PIONEERING CORPORATE AUDITORSCynthia Cooper
2002WorldCom, Inc. • Vice President of Internal Audit
Cooper and her internal audit team conducted secret night audits that bypassed CFO Scott Sullivan, uncovering $3.8B in operating line costs improperly moved to capital accounts.
Regulatory Outcome: WorldCom admitted to $11B in false accounting, triggering bankruptcy and the passage of the Sarbanes-Oxley Act of 2002.
Sherron Watkins
2001Enron Corp. • Vice President of Corporate Development
Watkins authored a confidential seven-page memo to Chairman Kenneth Lay warning that Enron would 'implode in a wave of accounting scandals' due to off-balance-sheet Raptor partnerships.
Regulatory Outcome: Exposed off-balance-sheet special purpose entities, leading to criminal indictments and the dissolution of Arthur Andersen LLP.
Tyler Shultz & Erika Cheung
2015Theranos, Inc. • Laboratory Associates
Disclosed that Theranos secretly diluted patient blood samples and ran tests on modified commercial Siemens analyzers instead of proprietary Edison devices.
Regulatory Outcome: Triggered federal CMS laboratory shutdowns, SEC civil fraud charges, and federal criminal wire fraud convictions.