On March 4, 2019, the U.S. Commodity Futures Trading Commission (CFTC) issued a whistleblower award totaling more than $2 million to be paid to an individual whistleblower, as part of its Dodd-Frank whistleblower program. This award is particularly interesting because the whistleblower “provide[d] critical information through independent analysis of market data,” according to the CFTC press release, but was not a corporate insider.

The Director of the Whistleblower Office, Christopher Ehrman, said in the press release that the award “illustrates two key aspects of our Whistleblower Program — that an individual doesn’t have to be an insider to receive a whistleblower award and the Commission can pay awards based on related actions brought by other regulators.”

The CFTC Order highlighted that the whistleblower’s original information caused the CFTC to open an investigation and bring a successful covered action. It also highlighted that the information led, in part, to the initiation and resolution of a related action brought by an unnamed “Federal Regulator.” The whistleblower was lauded by the CFTC Order for providing the Staff with “assistance and analysis in interpreting voluminous data” during the investigation.

This is the CFTC’s first award of 2019 and only the sixth award issued since the inception of its whistleblower bounty program created by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. As is the case with the CFTC’s prior awards, the Agency did not provide details about the whistleblower or the information that led to the enforcement action.