The Securities and Exchange Commission (SEC) today released its Annual Report to Congress on the Dodd-Frank Whistleblower Program for Fiscal Year 2025, which detailed the millions of dollars awarded to more than two dozen whistleblowers who reported corporate misconduct and assisted with ensuing government investigations. 

The report also pointed to a slowdown in enforcement activity as the agency adjusted to a 17% reduction in headcount during the year, as well as evolving enforcement priorities under the new administration. The Commission awarded more than $60 million to 48 individual whistleblowers—a drop from the $255 million it awarded in fiscal year (FY) 2024. Nevertheless, the decline in awards must be viewed against the 2025 Agency Financial Report, released by the SEC on January 16, 2026 in which the Commission set forth a range for probable contingent liabilities for FY 2025 whistleblower awards between $218 million – $655 million. The range will depend on the amount of the whistleblower awards, which under statute can be 10% – 30% of monetary sanctions levied against bad actors in an enforcement action.  

“These contingent liabilities underscore that the whistleblower program’s financial footprint extends well beyond the awards announced in any single fiscal year. More importantly, it suggests that significant award obligations remain in the pipeline,” said Dave Jochnowitz, Co-Chair of Outten & Golden’s Whistleblower & Retaliation Practice Group. 

In addition to the lean enforcement staff, the Commission has also consolidated field offices, changed reporting structures, and disbanded some enforcement units as it seeks to zero in on traditional investor harm cases. These matters include market manipulation, insider trading, and offering fraud, among others.

“With 27,000 tips submitted in the last fiscal year, the agency is forced to do more with less. In that regard, more than ever, the Commission needs whistleblowers to come forward with early, actionable intelligence about securities fraud,” Jochnowitz continued. 

According to the report, during FY 2025 the SEC:

• Issued whistleblower awards totaling more than $60 million, recognizing 48 individuals whose information led to successful enforcement actions.
• Made 82 Preliminary Determinations recommending awards, suggesting FY 2026 will be another strong year for the program.
• Received approximately 27,000 tips from individuals across the United States and abroad, roughly 8% more than the prior year, reflecting sustained public awareness and confidence in the program.
• Saw the most tips originate outside of the United States from Canada, the United Kingdom, Italy, Germany, and China.
• Received tips alleging a broad range of misconduct, including manipulation (28%); offering fraud (27%); corporate disclosures and financials (11%); and, cryptocurrencies and crypto asset securities (7%).
• Finished the fiscal year with nearly $319 million in the Investor Protection Fund from which whistleblower awards are paid.  

Commitment to Confidentiality and Anti-Retaliation Protections 

The FY 2025 report also details the SEC’s continued effort to shield whistleblowers with the program’s confidentiality and anti-retaliation provisions. Under the rules, employers cannot terminate, demote, suspend, harass, or in any way discriminate against an employee who reports possible violations of the federal securities laws. In addition, whistleblowers who report to the SEC have the right to file a retaliation complaint in federal court seeking double back pay with interest, reinstatement, reasonable attorneys’ fees, and reimbursement for certain litigation costs. 

The SEC also took steps to ensure that employers cannot stop whistleblowers from coming forward. In one enforcement action, two investment advisers agreed to pay a total of $90 million to resolve charges that they used unlawful separation agreements to impede whistleblowers from reporting potential securities violations to the SEC. Specifically, the defendants required nearly 300 departing employees to represent that they had not filed any complaints against the companies in order to receive severance payments. The SEC has routinely held that such agreements are not enforceable.

“The SEC has taken a strong stance to keep reporting lines open. It can and should continue to encourage whistleblowing by holding companies accountable for silencing employees through unlawful separation agreements,” noted Tammy Marzigliano, Co-Chair of Outten & Golden’s Whistleblower & Retaliation Practice. “Robust employment protections and the ability to report anonymously when working with an attorney are central to the SEC’s program, and key drivers of its success,” Marzigliano added.