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Wait for it: CFTC Awards $1.25 Million to Whistleblower Under New 120-Day Safe Harbor Provision

Date Published
Apr 12, 2024

APRIL 12, 2024. The Commodity Futures Trading Commission (CFTC) announced that they are awarding $1.25 million to a whistleblower who worked within the offending entity’s auditing and compliance branch. This is the first award given under the CFTC’s 120-day safe harbor provision, which requires a whistleblower who works in those functionalities to raise concerns internally and wait at least 120 days and see no meaningful changes before contacting the CFTC.

The Director of the CFTC’s Whistleblower Office detailed the provision’s steps, explaining that “the whistleblower first reported internally, fulfilling job duties and putting the entity on notice of its wrongdoing … The CFTC’s Whistleblower Program rewards employees with compliance and audit responsibilities who first raise violations internally and then contact the CFTC if the employer sits on its hands.”

The CFTC’s Director of the Division of Enforcement applauded the whistleblower, emphasizing that “insiders have some of the most valuable evidence about illegal activity in our markets … Today’s award recognizes the risks they take in coming forward to the CFTC, as well as the role of their information in amplifying the CFTC’s enforcement efforts.”

The CFTC’s whistleblower program is entering its fourteenth year, created in 2010 by Congress under the Dodd-Frank Wall Street Reform Act. Since its inception, the CFTC has awarded whistleblowers approximately $365 million and collected over $3.2 billion in monetary sanctions from entities who violate the CFTC’s laws. The Commodity Exchange Act (CEA) protects whistleblowers’ identities and ensures that regardless of whether the CFTC grants an award, they will not disclose any information that could reveal a whistleblower’s identity, with few exceptions.

If you would like to report securities, commodities, and banking fraud, you can contact attorneys at Tycko & Zavareei LLP.  Eva Gunasekera and Renée Brooker are former officials of the United States Department of Justice and prosecuted whistleblower cases under the False Claims Act and FIRREA. Renée served as Assistant Director at the United States Department of Justice, the office that supervises False Claims Act and FIRREA cases in all 94 United States District Courts. Eva was the Senior Counsel for Health Care Fraud. Eva and Renée now represent whistleblowers. For a free consultation, you can contact Renée at [email protected] (tel.: 202-417-3664) or contact Eva Gunasekera at [email protected]. You can also go to Tycko & Zavareei LLP’s website for whistleblowers to learn more at

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