In the Matter of the Claim for Award
An anonymous whistleblower received a $1.2 million SEC award for using a custom algorithm to analyze publicly available data and uncover previously undisclosed securities violations, significantly aiding the investigation and settlement of a covered enforcement action.
The SEC awarded an anonymous whistleblower approximately $1.2 million, representing a percentage of monetary sanctions collected in a covered enforcement action, for providing original, voluntary information through independent analysis. The claimant developed and applied a complex algorithm to publicly available data, revealing non-public insights that bridged the gap between open information and actionable evidence of securities violations. This early and ongoing assistance—through multiple communications—saved the SEC time and resources and contributed directly to the success of the investigation and settlement, qualifying the claimant under Rule 21F-4(b)(3); no related action award was granted, and the claimant did not contest its denial.
The U.S. Securities and Exchange Commission (SEC) awarded an anonymous whistleblower approximately $1.2 million, representing a percentage of monetary sanctions collected in a covered enforcement action, for providing original, voluntary information that significantly advanced the investigation. The claimant used independent analysis—creating and applying a complex algorithm to publicly available data—to uncover previously undisclosed securities violations, thereby fulfilling the regulatory definition of 'independent analysis' under Rule 21F-4(b)(3) by revealing non-public insights that bridged the gap between open information and actionable evidence. The whistleblower’s early submission enabled the SEC to conserve time and resources, and their ongoing cooperation through multiple phone calls and emails played a critical role in shaping the investigation and supporting settlement negotiations. The Commission determined that the claimant’s analysis was revelatory, going beyond mere aggregation of public data to provide unique, actionable intelligence. Although the SEC also considered a related action award, the claimant did not contest its preliminary denial, making that denial final. The exact percentage of the award and the identity of the entity penalized remain redacted, as do details of the underlying violations. This case underscores the SEC’s commitment to rewarding innovative, data-driven whistleblowing that transforms public information into enforcement-ready evidence.
Extracted insights
- $1.20M $1.2 million $1M–$10M
- person Claimant
- person claims review staff
- agency Securities and Exchange Commission
- person Vanessa a. Countryman
- Claims Review Staff recommended whistleblower award of approximately $1.2 million
- Commission adopted recommendation of the Claims Review Staff
- Claimant provided original information to the Commission
- Claimant created complex algorithm to publicly available data
- Claimant provided ongoing assistance to the staff
- Commission ordered Claimant shall receive an award
UNITED STATES OF AMERICA Before the SECURITIES AND EXCHANGE COMMISSION SECURITIES EXCHANGE ACT OF 1934 Release No. 92777 / August 27, 2021 WHISTLEBLOWER AWARD PROCEEDING File No. 2021-85 In the Matter of the Claim for Award in connection with Notice of Covered Action ORDER DETERMINING WHISTLEBLOWER AWARD CLAIM The Claims Review Staff (“CRS”) issued a Preliminary Determination recommending that (“Claimant”) receive a whistleblower award of approximately $1.2 million, which represents percent ( %) of the monetary sanctions collected or to be collected in the above-referenced Covered Action (the “Covered Action”). 1 The recommendation of the CRS is adopted. The record demonstrates that Claimant voluntarily provided original information to the Commission, and that this information led to the successful enforcement of the Covered Action. 2 1 The CRS also recommended the denial of a related action award to Claimant. Because Claimant did not contest the preliminary denial, the CRS’s preliminary determination as to the denial of the related action award became the final order of the Commission pursuant to Exchange Act Rule 21F-11(f); 17 C.F.R. § 240.21F-11(f). 2 See Securities Exchange Act of 1934 (“Exchange Act”) Section 21-F(b)(1), 15 U.S.C. § 78u-6(b)(1); Exchange Act Rule 21F-3(a), 17 C.F.R. § 240.21F-3(a). In reaching this determination, the Commission considered that Claimant provided new and useful information to Commission staff based on Claimant’s “independent analysis,” 6 by creating and applying a complex algorithm to publicly available data and sharing Claimant’s own knowledge and experience using the publicly available data. Claimant’s information, provided early in the investigation, allowed the staff to conserve time and resources and assisted the staff during settlement negotiations with the company, which significantly contributed to the success of the Covered Action. Claimant also provided ongoing assistance to the staff during the investigation through multiple phone calls and emails. 6 See Rule 21F-4(b)(3) (defining “independent analysis” as “[t]he whistleblower’s] own analysis, whether done alone or in combination with others. Analysis means [t]he whistleblower’s] examination and evaluation of information that may be publicly available, but which reveals information that is not generally known or available to the public”). To be credited with providing “independent analysis,” the whistleblower’s examination and evaluation should contribute significant independent information that “bridges the gap” between the publicly available information and the possible securities violations. “[I]n each case, the touchstone is whether the whistleblower’s submission is revelatory in utilizing publicly available information in a way that goes beyond the information itself and affords the Commission with important insights or information about possible violations.” Adopting Release for Amendments to Whistleblower Rules, Exchange Act Release No. 34-89963 (Sept. 23, 2020) at 112-13. 2
UNITED STATES OF AMERICA Before the SECURITIES AND EXCHANGE COMMISSION SECURITIES EXCHANGE ACT OF 1934 Release No. 92777 / August 27, 2021 WHISTLEBLOWER AWARD PROCEEDING File No. 2021-85 In the Matter of the Claim for Award in connection with Notice of Covered Action ORDER DETERMINING WHISTLEBLOWER AWARD CLAIM The Claims Review Staff (“CRS”) issued a Preliminary Determination recommending that (“Claimant”) receive a whistleblower award of approximately $1.2 million, which represents percent ( %) of the monetary sanctions collected or to be collected in the above-referenced Covered Action (the “Covered Action”). 1 The recommendation of the CRS is adopted. The record demonstrates that Claimant voluntarily provided original information to the Commission, and that this information led to the successful enforcement of the Covered Action. 2 1 The CRS also recommended the denial of a related action award to Claimant. Because Claimant did not contest the preliminary denial, the CRS’s preliminary determination as to the denial of the related action award became the final order of the Commission pursuant to Exchange Act Rule 21F-11(f); 17 C.F.R. § 240.21F-11(f). 2 See Securities Exchange Act of 1934 (“Exchange Act”) Section 21-F(b)(1), 15 U.S.C. § 78u-6(b)(1); Exchange Act Rule 21F-3(a), 17 C.F.R. § 240.21F-3(a). In reaching this determination, the Commission considered that Claimant provided new and useful information to Commission staff based on Claimant’s “independent analysis,” 6 by creating and applying a complex algorithm to publicly available data and sharing Claimant’s own knowledge and experience using the publicly available data. Claimant’s information, provided early in the investigation, allowed the staff to conserve time and resources and assisted the staff during settlement negotiations with the company, which significantly contributed to the success of the Covered Action. Claimant also provided ongoing assistance to the staff during the investigation through multiple phone calls and emails. 6 See Rule 21F-4(b)(3) (defining “independent analysis” as “[t]he whistleblower’s] own analysis, whether done alone or in combination with others. Analysis means [t]he whistleblower’s] examination and evaluation of information that may be publicly available, but which reveals information that is not generally known or available to the public”). To be credited with providing “independent analysis,” the whistleblower’s examination and evaluation should contribute significant independent information that “bridges the gap” between the publicly available information and the possible securities violations. “[I]n each case, the touchstone is whether the whistleblower’s submission is revelatory in utilizing publicly available information in a way that goes beyond the information itself and affords the Commission with important insights or information about possible violations.” Adopting Release for Amendments to Whistleblower Rules, Exchange Act Release No. 34-89963 (Sept. 23, 2020) at 112-13. 2