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SEC

SEC

Securities and Exchange Commission (US)

Low Impact

SEC Determines Whistleblower Awards for Related Agency Action

Published

Sep 28, 2026

Topics

Whistleblower awards, SEC enforcement, Related actions, Internal reporting, Compliance investigations

Executive Summary

The Securities and Exchange Commission issued an order determining whistleblower award claims connected with a redacted enforcement matter and a related action brought by another agency. The Commission adopted the Claims Review Staff’s preliminary determinations that the other agency’s action qualifies as a “related action” under Exchange Act Rules 21F-3(b) and 21F-4(d)(3)(i), and that two claimants are eligible for awards from monetary sanctions collected in that action. The order states that the claimants voluntarily provided the same original information to the Commission and the other agency, and that the information led to successful enforcement. The Commission applied the award factors in Rule 21F-6, including significance of information, assistance provided, participation in internal compliance systems, culpability, unreasonable delay, and interference with internal reporting. This is not a rulemaking and does not impose new obligations. Its practical importance is as precedent and control intelligence for whistleblower intake, escalation, internal investigation documentation, and cross-agency enforcement-response processes.

What Changed

newAward determination issued

Previous

The Claims Review Staff had issued preliminary determinations recommending eligibility and award percentages, and the claimants did not contest them.

New

The Commission adopted the preliminary determinations and ordered payment of the award percentages stated in the redacted order.

newRelated-action treatment confirmed for this matter

Previous

Related-action status was a staff recommendation in the preliminary determinations.

New

The Commission accepted the related-action determination under Exchange Act Rules 21F-3(b) and 21F-4(d)(3)(i).

newAward allocation factors applied

Previous

Award percentages were recommended by the Claims Review Staff based on the record.

New

The Commission finalized different award allocations, noting that one claimant’s information opened the investigation but was limited and delayed, while the other provided more significant assistance and internally reported the conduct.

newOperational precedent for internal compliance documentation

Previous

No new internal reporting obligation is created by this order.

New

Compliance teams should treat the order as enforcement-program intelligence for documenting intake, escalation, investigation steps, and interactions with regulators.

Business Impact

Who is affected

Directly affected

the two whistleblower claimants in the SEC award proceeding and the SEC whistleblower award administration process.

Indirectly affected

SEC-regulated firms, public companies, broker-dealers, investment advisers, issuers, compliance officers, legal teams, internal audit, HR investigations teams, and personnel managing whistleblower intake or regulator cooperation.

Jurisdictions

United States

Business processes

Whistleblower intake and triage, Internal investigation documentation, Escalation to legal and compliance leadership, Regulator cooperation and agency-contact tracking, Monitoring of SEC whistleblower orders for enforcement trends

Estimated effort

Low

Compliance risk

Low

Affected Reports

Whistleblower intake and escalation registerInternal investigation case fileRegulator contact and cooperation logRelated-action and enforcement-monitoring trackerWhistleblower program governance control review
FieldValidation rule

Recommended Actions

6 suggested next steps· derived from source analysis
  1. 1
    AI generatedStep 1 of 6

    Treat this as precedent and control intelligence, not a new binding reporting requirement or rule amendment.

  2. 2
    AI generatedStep 2 of 6

    Review whistleblower intake procedures to ensure tips, dates, escalation decisions, and internal follow-up are documented contemporaneously.

  3. 3
    AI generatedStep 3 of 6

    Confirm investigation files capture whether concerns were raised internally, when they were raised, and what action the company took.

  4. 4
    AI generatedStep 4 of 6

    Maintain a regulator-interaction log where matters involve potential parallel or related agency investigations.

  5. 5
    AI generatedStep 5 of 6

    Train compliance, legal, HR, and internal audit teams on the SEC’s award-factor themes, including significance of information, assistance, internal reporting, and delay.

  6. 6
    AI generatedStep 6 of 6

    Monitor future SEC whistleblower orders for recurring treatment of related actions and internal compliance participation.

Timeline

other

Aug 26, 2024

SEC issued a prior whistleblower award order to Claimant 1 and Claimant 2 in connection with an SEC covered action and another related action, as referenced in the 2026 order.

publication

Sep 28, 2026

SEC issued Release No. 34-106513, Order Determining Whistleblower Award Claims, File No. 2026-46.

Sources

AI-generated analysis is based on the following primary sources. Always verify against the official publication.

Related Evidence

Verified source support for this analysis

The evidence agent checks whether the drafted finding is supported by official publications and relevant public source material.

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