On December 19, 2025, the Commodity Futures Trading Commission (CFTC) announced that it awarded more than $1.8 million to two whistleblowers whose tips and cooperation were instrumental in helping the Commission identify fraud and return funds to harmed investors. While the CFTC keeps the details of underlying actions confidential to protect whistleblowers’ identities, the case underscores the critical role whistleblowers play in protecting investors and the integrity of the markets.
According to the CFTC’s final order, the two whistleblowers voluntarily provided original information that significantly contributed to the Commission’s investigation and resolution of the case. Their assistance included timely and detailed cooperation throughout the enforcement process.
Notably, five other claimants applied for awards in connection with the same action but were denied because their information did not meaningfully contribute to the underlying action or they were otherwise statutorily ineligible.
What Is the CFTC Whistleblower Program?
Established under the Dodd-Frank Act in 2010, the CFTC Whistleblower Program incentivizes individuals to report violations of the Commodity Exchange Act (CEA), such as market manipulation, fraud, and other misconduct in the commodities and derivatives markets. Since its first award in 2014, the program has distributed over $395 million to whistleblowers, whose tips led to more than $3.3 billion in total monetary sanctions.
Similar to the SEC Whistleblower Program, eligible CFTC whistleblowers can receive between 10-30% of monetary sanctions collected in enforcement actions where the penalties exceed $1 million. All awards are paid from the CFTC’s Customer Protection Fund—not from taxpayers or harmed investors.
Confidentiality is a cornerstone of the program. It offers strong anti-retaliation protections, and whistleblowers may file anonymously when represented by an attorney. The Commission is required not to disclose information that could reasonably be expected to reveal a whistleblower’s identity, with very limited exceptions. While the CFTC takes this obligation seriously, hiring experienced counsel is the safest bet to prevent inadvertent disclosure of personally identifiable information.
What to Do If You Spot Commodities Fraud
Original, timely, and specific information matters. To qualify for an award, the tip must lead to or significantly contribute to a successful enforcement action of more than $1 million. You will not be eligible for an award if you report fraud that the Commission already knows about, or if your information does not meaningfully help the CFTC’s enforcement efforts.
Whistleblowers may file tips anonymously with or without an attorney, but they must be represented by counsel to apply for an award anonymously.
Cooperation also counts. If the CFTC decides to pursue an investigation or enforcement action based on your tip, you’ll likely be asked to provide additional information to CFTC officials during their investigation. The CFTC considers the extent of the whistleblower’s cooperation when making its final award determination.
Certain individuals may be statutorily barred from receiving awards, such as members of registered entities or anyone convicted of a crime related to the underlying action. There are numerous eligibility criteria and other program rules, and these rules can be quite complex. Hiring an experienced attorney is the safest option for whistleblowers who wish to maximize eligibility for an award and stay legally protected from retaliation.
Thinking About Coming Forward? Get In Touch with Us.
If you have evidence of commodities fraud, or have already reported it and have suffered retaliation, our firm can help. Outten & Golden’s experienced Whistleblower & Retaliation attorneys have decades of experience representing individual whistleblowers and have secured precedent-setting decisions and financial awards.
