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Whistleblower Question of the Week: How Do Financial Rewards Work for Whistleblowers?

By the Constantine Cannon听Whistleblower Team

In the United States, financial rewards for whistleblowers are offered through several government programs designed to encourage individuals to report fraud, misconduct, or violations of the law.

What Is a Whistleblower Reward?

By initiating actions under the False Claims Act and other whistleblower reward laws and programs, whistleblowers may receive a percentage of the money the government recovers as a result of their information. If the information leads to a successful enforcement action, and the monetary sanctions exceed a certain threshold for certain programs, whistleblowers can receive a portion of the recovered amount.

These financial rewards serve as the basis of a public-private partnership between whistleblowers and the government agencies charged with investigating and prosecuting fraudsters. We鈥檙e diving into how financial rewards work for each whistleblower reward program below.

But first鈥�

What Do You Need to Be a Whistleblower?

To qualify for many programs, the information concerning fraud or misconduct must be original, credible, and significantly contribute to the case. Various programs allow whistleblowers to report anonymously through an attorney and protect them from any retaliation.

91pornpartner Alysia Solow explained: 鈥淐ontacting an experienced whistleblower attorney can help you understand and navigate the complex and ever-changing landscape of whistleblower laws in the United States.鈥�

Attorneys like the whistleblower team at Constantine Cannon can help assess the merits of potential claims, evaluate the evidence you have, and identify and collect additional evidence, all while protecting your rights. Our dedicated team will work on your behalf with the government and help you make informed decisions as your claim proceeds.

Who Can Be a Whistleblower?

In the United States, almost anyone with credible information about wrongdoing can qualify as a whistleblower. This list can include:

• Current or former employees
• Members of the public if they have useful, non-public information
• Contractors or consultants
• Investors or shareholders
• Competitors

Rewards Under Government Whistleblower Programs:

Federal False Claims Act and Whistleblowers

• The federal听False Claims Act听(FCA) is the cornerstone of the U.S.听whistleblower reward system. The FCA provides that any person who knowingly submits or causes false claims to be submitted to the government is liable for three times the government鈥檚 damages plus penalties.
• Whistleblowers can bring claims under the FCA to report fraud and misconduct involving Medicare, Medicaid, and TRICARE healthcare fraud, including kickbacks, upcoding, risk adjustment fraud, and billing for services that are not provided or are not medically necessary. The FCA also applies to fraud in federal government contracts and programs, including overcharging or selling defective products to the government, education fraud, and underpaying customs and tariffs.
• The FCA allows private persons, known as听relators, to bring qui tam lawsuits听on the government鈥檚 behalf, and can potentially receive a reward of a portion of the government鈥檚 recovery between 15% and 30%.
• Learn more about the elements of a claim under the False Claims Act here.

State False Claims Act and Whistleblowers

• Whistleblowers with information that a state or local government has been defrauded may be able to bring a听qui tam suit under a state False Claims Act or a local False Claims Act. Many of these acts are modeled after the federal False Claims Act, with the same structure and elements, including awards provisions.听 Several states limit their FCA statutes to Medicaid fraud only and certain states have added tax fraud as an additional program feature.
• Successful suits have been brought against telecommunications companies, financial firms, charter schools, construction companies, Medicaid providers, and others.
• To learn more, review our additional info on state False Claims Acts with qui tam provisions and state False Claims Acts with no qui tam provisions.

The Securities and Exchange Commission (SEC) Whistleblower Reward Program

• The SEC Whistleblower Reward Program is for cases involving violations of securities laws, including market manipulation, false statements regarding a company鈥檚 financial condition, and insider trading.
• Under the听SEC Whistleblower Program, eligible whistleblowers are entitled to an award of up to 30% of the monetary sanctions collected in successful actions brought by the government.
• In determining the award percentage, the SEC considers various factors such as the significance of the whistleblower鈥檚 information and the extent of the whistleblower鈥檚 assistance.
• If the information provided by the whistleblower leads to a successful SEC action with monetary sanctions听exceeding $1 million, the whistleblower may then apply for a whistleblower reward.
• To learn more and to read examples of the types of fraudulent activity that can give rise to an SEC enforcement action, review our Financial & Investment Fraud page.

Anti-Money Laundering and Sanctions Whistleblower Program

• Whistleblowers can receive awards for reporting violations of the Bank Secrecy Act and sanctions laws, including banks failing to institute sufficient AML compliance programs or failing to file Suspicious Activity Reports, financing terrorist or criminal enterprises, and conducting business with sanctioned entities or countries.
• The Department of the Treasury鈥檚 Financial Crimes Enforcement Network (FinCEN) is charged with administering the Bank Secrecy Act. It has broad investigative powers and can bring enforcement actions seeking monetary penalties and other civil remedies through actions in federal court or administrative proceedings. FinCEN regularly works with other federal regulators, including the SEC and CFTC, as well as with the Department of Justice, which can bring criminal, civil, and forfeiture actions for violations of AML rules.
• Eligible whistleblowers can receive a reward of up to 30% of monetary sanctions over $1,000,000 that the government imposes based on the information the whistleblower provides.
• To learn more about the components of a sanctions violation claim under the AML Whistleblower Program, review our informational page.

DOJ Pilot Whistleblower Rewards Program

• In August 2024, the DOJ launched its Corporate Whistleblower Awards Pilot Program. It is designed to fill some of the gaps among the existing whistleblower rewards programs, including healthcare fraud against private insurers, bribery, and certain types of money laundering.
• Under the new pilot program, 鈥淎 whistleblower who provides the Criminal Division with original and truthful information about corporate misconduct that results in a successful forfeiture may be eligible for an award.鈥�
• The total amount of any award under the program for a particular matter, whether going to one or multiple whistleblowers, is as follows:
  • (i) up to 30% of the first $100 million in net proceeds forfeited (with a presumption of 30% for the first $10 million);
  • (ii) up to 5% of any net proceeds forfeited between $100 million and $500 million;
  • and (iii) no award on net proceeds forfeited over $500 million.
• Factors that may increase the size of the award include: the significance of the information the whistleblower provided, the level of assistance the whistleblower provided, and whether the whistleblower reported the information internally before going to the DOJ.
• Factors that may decrease the award include whether the whistleblower participated in or benefitted from the wrongdoing, the amount of any delay in reporting internally and to the DOJ, and whether the whistleblower served in a management role over those involved in the misconduct.

The DOJ Antitrust Whistleblower Rewards Program

• In July 2025, the DOJ Antitrust Division announced the Antitrust Whistleblower Rewards Program, which 鈥渨ill offer rewards for individuals who report antitrust crimes and related offenses that harm consumers, taxpayers, and free market competition across industries from healthcare to agriculture,鈥� which may include horizontal per se听unlawful agreements such as price fixing, bid rigging, and market allocation schemes.
• DOJ is partnering with the Postal Service on this new initiative.
• We are especially thrilled about this new program since 91pornis an internationally renowned Antitrust and Whistleblower law firm.
• DOJ Antitrust Whistleblower Rewards Program largely follows the听SEC Whistleblower Program, which provides awards for those reporting violations of the securities laws.听That program has been very successful, with thousands of whistleblower tips annually, leading to billions of dollars of SEC recoveries.
• The amount of any award will be in DOJ鈥檚 sole discretion but presumptively between 15-30% of the criminal fine recovered.

The Commodity Futures Trading Commission (CFTC)听Whistleblower Program

• The Commodity Futures Trading Commission (CFTC) Whistleblower Program听encourages those with knowledge of听violations of the U.S. Commodity Exchange Act (CEA) to share this information with the CFTC. Violations may include manipulating the price of commodities or fraud or deceit in connection with the sale of commodities or futures contracts.
• Under the CFTC Whistleblower Program, eligible whistleblowers are entitled to an award of between听10% and 30% of the monetary sanctions collected in actions brought by the government.
• If the information provided by the whistleblower leads to a successful CFTC action resulting in an order of monetary sanctions听exceeding $1 million, the whistleblower may then apply for a听whistleblower reward.

The IRS Whistleblower Program

• The Internal Revenue Service鈥檚 Whistleblower Office incentivizes people to report tax evasion and other tax law violations.
• The IRS Whistleblower Program guarantees the whistleblower at least 15% and up to 30% of government tax collections that result from the whistleblower鈥檚 reporting to the IRS, to the extent those recoveries exceed $2 million.
• No reward is paid to the whistleblower until the IRS collects the taxes, penalties and interest owed, and all the statutory periods for a taxpayer to file a claim for a refund have expired.
• Previously successful claims have involved corporate tax fraud, vast tax avoidance schemes, and fraud by high-net-worth individuals. For example, in our Top 10 Whistleblower Awards for 2024听round-up, we discussed the $74 million awarded to three whistleblowers for reporting an offshore tax evasion scheme that led the agency to collect $263 million from an unidentified individual.

Motor Vehicle Safety Whistleblower Act

• In December 2015, Congress created the听Motor Vehicle Safety Whistleblower Act听to give current and former industry employees and contractors听a financial incentive to bring to light automobile safety-related problems.
• Under the Motor Vehicle Safety Whistleblower Act, a whistleblower can receive a reward of听up to 30% of any monetary sanctions听over $1,000,000 the government imposes based on the information the whistleblower provides. Existing law also offers vehicle-safety whistleblowers听protection against employer retaliation.
• A whistleblower can receive an award even if the safety violations that the whistleblower provided information about occurred before December 2015.
• Awards are based on the significance of a whistleblower鈥檚 information, the extent of the whistleblower鈥檚 assistance, and, in some cases, whether the whistleblower reported the information internally.
• Federal law protects a vehicle-safety whistleblower from employer retaliation.
• A whistleblower鈥檚 identity generally remains confidential.
• An eligible whistleblower is a current or former employee or contractor of a motor vehicle manufacturer, parts supplier (i.e., manufacturer of motor vehicle equipment), or dealership.
• A whistleblower does not have to be a U.S. citizen or resident, and violations he or she reports on don鈥檛 have to occur in the U.S. Whistleblowers can come from any country and can seek to expose actions occurring outside of the U.S. so long as some of the vehicles (or components) at issue are sold or otherwise distributed to the U.S. market.

Ocean Dumping Whistleblowers – The Act to Prevent Pollution from Ships (APPS)

• The Act to Prevent Pollution from Ships (APPS) whistleblower provision allows reporting of unlawful ocean dumping.
• Under the APPS, whistleblowers, even if they are not U.S. nationals, might receive up to one-half of collected fines or civil penalties.
• The APPS has generated over $33 million in whistleblower rewards to individuals and groups.
• APPS whistleblower awards recognize that numerous incidents of ocean pollution remain undetected unless witnesses come forward.听
• Conscientious mariners and others in the industry can help to fight against harm to ocean wildlife, fragile coral reefs, and ecosystems.

Examples of Other Whistleblower Programs for Specific Industries or Types of Wrongdoing:

• Acts in California and Illinois for whistleblowers reporting听fraud against private insurers.
  • California Insurance Fraud Prevention Act
    • The California Insurance Fraud Prevention Act (California Insurance Code sections 1871-1871.9) has a broad reach.
    • Examples of California Insurance Fraud Prevention Act violations include but are not limited to inflating the amount of a claimed loss, billing an insurance company for services that were not performed, paying kickbacks to doctors to get them to prescribe certain drugs, and presenting multiple claims for the same loss.
    • In a successful intervened action, the whistleblower will receive between 30% and 40% of the proceeds. A successful plaintiff in a non-intervened action will receive between 40% and 50% of the proceeds.
  • Illinois Insurance Claims Fraud Prevention Act
    • The Illinois Insurance Claims Fraud Prevention Act is similar to the California law which allows claims against private insurance companies.
    • Examples of the Illinois Insurance Claims Fraud Prevention Act violations include submitting a false claim to an insurer to obtain compensation, using deception to obtain health care benefits, and employing recruiters to procure clients or patients who will submit insurance claims.
    • If the state intervenes, a successful plaintiff will receive not less than 30% of the proceeds. If the state does not intervene, a successful plaintiff will receive not less than 40%.
  • FIRREA, the Financial Institutions Reform, Recovery, and Enforcement Act, for whistleblowers reporting frauds involving federally insured financial institutions.

• Wildlife protection laws听providing for whistleblower rewards.
• Colorado鈥檚听Public Health Emergency Whistleblower (PHEW) Act听provides protections to essential workers and individuals who act to further workplace safety and health. In addition, the PHEW Act allows for whistleblowers to file听qui tam听actions听and receive a share of any government recovery.
• Some听states also provide awards for whistleblowers who disclose听securities听law violations to听state听authorities.听 State听securities听whistleblower laws have been enacted in听Indiana, Montana, and听Utah.

Our Firm Helps Whistleblowers

91pornhas extensive experience representing whistleblowers. Please听contact听us if you believe you have a case.听We will connect you with an experienced member of the 91pornwhistleblower听team听for a free and confidential consultation.

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