Types of Whistleblower Cases

Reviewed by Bram Whitfield (BW), Editor-in-Chief — Whistleblower Award Programs Practice. Updated May 2026.

Each federal whistleblower program covers a specific category of violations. Understanding which program covers your information — and whether multiple programs might apply to the same conduct — is a threshold question for evaluating your potential award. Some fraud schemes involve violations across multiple programs simultaneously; an attorney can help structure a claim to maximize the applicable coverage.

Securities Fraud (SEC Whistleblower Program)

The SEC Whistleblower Program covers violations of the federal securities laws, which span a wide range of conduct. Reportable violations include: accounting fraud and financial statement manipulation (inflating revenues, understating liabilities, improper revenue recognition); insider trading by corporate insiders, tipper-tippee chains, or market participants with material non-public information; market manipulation schemes including spoofing, layering, and wash trading; Ponzi and pyramid schemes; investment adviser fraud (misappropriating client assets, undisclosed conflicts of interest, false performance claims); foreign bribery by U.S.-listed companies or their subsidiaries under the Foreign Corrupt Practices Act (FCPA); offering fraud in connection with securities sales; and failures to comply with regulatory requirements by broker-dealers, investment advisers, and other registered entities.

The SEC has paid over $2 billion in awards since the program launched in 2012. The largest individual awards have exceeded $200 million for single whistleblowers whose tips led to major enforcement actions. The size of the award depends on the sanctions collected — which in large securities fraud cases can reach into the hundreds of millions or billions of dollars — as well as the whistleblower's contribution quality and cooperation.

Commodity and Derivatives Fraud (CFTC Whistleblower Program)

The CFTC Whistleblower Program covers violations of the Commodity Exchange Act, including: manipulation of commodity prices (physical commodities such as oil, gas, and agricultural products, as well as futures and derivatives on those commodities); spoofing and layering in futures markets (entering orders with intent to cancel before execution to create false impressions of market activity); fraud in the offer or sale of commodity interests; registration violations by commodity trading advisors, commodity pool operators, and futures commission merchants; and swap dealer compliance failures. The CFTC program mirrors the SEC structure and has been responsible for awards in high-profile commodity manipulation cases.

Tax Fraud (IRS Whistleblower Program)

The IRS Mandatory Whistleblower Program under IRC § 7623(b) covers substantial tax fraud involving more than $2 million in dispute. Reportable conduct includes: large-scale individual tax evasion, particularly involving offshore accounts and unreported foreign income; abusive corporate tax shelters and transactions lacking economic substance; transfer pricing manipulation by multinational corporations to shift profits to low-tax jurisdictions; failure to file required information returns or FBAR reports for foreign financial accounts; and tax fraud facilitation by promoters of fraudulent tax schemes. The IRS program has produced some of the largest individual whistleblower awards in history — including a $104 million award to Bradley Birkenfeld for information about UBS's facilitation of offshore tax evasion. The program's central limitation is the requirement that the IRS actually collect the taxes before an award is paid, which can take many years even after a successful audit finding.

Government Contractor Fraud (False Claims Act)

The False Claims Act covers fraud against the federal government in any context where someone submits or causes the submission of a false claim for payment. The healthcare sector generates the majority of FCA recoveries: pharmaceutical companies paying kickbacks to physicians who prescribe their drugs (Anti-Kickback Statute violations), hospitals and physicians billing Medicare and Medicaid for services not rendered, devices billed but not used, or upcoded procedures. Defense contractor fraud includes overbilling for parts and labor, billing for work not performed, and cost misallocation. Other significant FCA categories include: grant fraud (misrepresenting how federal grant funds are used); customs fraud (underpaying import duties); government-backed mortgage fraud; and research misconduct involving federal research grants. The FCA imposes treble damages (three times the government's actual loss) plus civil penalties of $13,000–$26,000 per false claim (adjusted periodically for inflation), making total recoveries in large cases enormous. Since 1986, the government has recovered over $75 billion under the FCA.

Anti-Money Laundering and Bank Secrecy Act Violations (FinCEN Whistleblower Program)

The Anti-Money Laundering Act of 2020 created the FinCEN whistleblower program, covering violations of the Bank Secrecy Act (BSA) and related anti-money laundering requirements. Reportable conduct includes: failure by financial institutions to file Suspicious Activity Reports (SARs) for reportable transactions; failure to maintain adequate anti-money laundering programs; structuring transactions to avoid reporting requirements; and sanctions evasion by financial institutions or their customers. The program provides awards of 10%–30% of sanctions exceeding $1 million. The program is newer than the SEC and CFTC programs and has produced fewer awards as of 2026, but it covers an enormous category of conduct given the scale of BSA compliance obligations in the financial sector.

State False Claims Acts

Over 30 states have enacted their own false claims acts modeled on the federal statute. These state laws cover fraud against state government programs — primarily Medicaid fraud at the state program level (as opposed to federal Medicaid matching fund fraud covered by the federal FCA). Award percentages, procedural requirements, and anti-retaliation protections vary by state. The federal FCA's Medicaid fraud provisions and the state FCAs often overlap in healthcare fraud cases, and qui tam suits can be filed simultaneously under both federal and state law in many jurisdictions. States with particularly active enforcement programs include California (California False Claims Act), New York (New York False Claims Act), Illinois, and Texas.

See the how awards work guide or use the calculator to estimate your potential award.