Introduction
Individuals anywhere in the world with information about securities fraud or a violation of the Securities Exchange Act are permitted to blow the whistle to the U.S. Securities and Exchange Commission (SEC) and potentially qualify for a substantial award.
These awards pay between 10% and 30% of the monetary sanctions collected when original information leads to a successful enforcement action.
The SEC Whistleblower Program was created by the Dodd-Frank Act after the 2008 global economic meltdown and is one of the most successful programs in the world. Since the inception of the SEC Whistleblower Program in 2011, a total of almost $2 billion has been awarded to nearly 400 whistleblowers — a figure that continues to climb each year.
These payouts are entirely funded by monetary sanctions paid to the SEC by securities law violators, and not from harmed investors.
The SEC whistleblower program is global by design. In fact, tips have come from roughly 130 countries since the program began, and in FY2025 alone the SEC received about 27,000 tips, with the highest numbers from abroad coming from Canada, the United Kingdom, Italy, Germany, and China.
Continue reading to learn how international whistleblowers can report securities fraud to the SEC and what to expect before, during, and after filing.
Before You Begin: SEC Whistleblower Self-Assessment
Before taking any additional steps, it’s important to keep any information to yourself until you’ve spoken with counsel. This is most critical if you live in a country with weak whistleblower protections or a history of retaliation against those who expose wrongdoing.
Below are the requirements for a strong SEC case:
- Specific, credible, and timely information about a possible violation of the U.S. federal securities laws.
- Confidence you’re reporting voluntarily — before any government inquiry on the matter reaches you.
- Original information from your independent knowledge or analysis, not already known to the SEC.
- A submission made directly to the SEC on Form TCR or through its online TCR portal — reporting to another agency or the media alone doesn’t qualify.
- Information that leads to a successful enforcement action with monetary sanctions exceeding $1 million.
- U.S. counsel if you intend to file anonymously — mandatory under SEC rules, not optional.
- Awareness of the 120-day window to file with the SEC if you first reported internally.
- Patience for a multi-year process from tip to investigation to award.
The largest single award in program history reached $279 million in 2023, and the SEC’s own financial reports show between $218 million and $654 million in probable awards still in the pipeline.
Attorneys with Inside Knowledge
International Whistleblower Advocates’ network includes attorneys behind some of the most significant international whistleblower cases ever brought to the SEC — and advocates who helped shape the rules.
For international whistleblowers, experienced U.S. counsel is critical. Filing anonymously requires a U.S.-based attorney who can help you draft a well-prepared submission to help you get the highest award percentage possible of the 10–30% range.
If you’d like to come forward and seek the best path forward, we suggest contacting our international securities fraud attorneys for a free and confidential consultation.
Step 1: Verifying Eligibility
As stated above, confirm that your information meets the SEC’s eligibility criteria. If you’re unsure, consult with an experienced whistleblower attorney first for greater clarity.
The SEC allows anyone, anywhere in the world to submit a tip — you don’t need to be a U.S. citizen, live in the U.S., or even work at the company you’re reporting. The SEC receives tips from all over the world and treats foreign sources no differently than domestic ones.
To be eligible for an award, your information must meet the following criteria:
- Voluntary: you must come forward on your own before the SEC, another regulator, or any U.S. federal authority directs a request or inquiry about the same matter to you or your representative.
- Original: information is derived from your independent knowledge or your own analysis — not from public sources, and not something the SEC already knows.
- Submitted to SEC: filing Form TCR or a submission through the SEC’s online TCR portal, signed under penalty of perjury, preserves your award rights. Reporting to your local regulator or the press alone does not qualify you.
- Over $1 Million Threshold Met: your tip must open a new investigation, reopen a closed one, push an existing one in a new direction, or significantly contribute to one already underway — and the resulting sanctions must exceed $1 million.
- Individual or Jointly: you can file alone or jointly with others, but a company or organization cannot be a whistleblower.
These are the basic requirements, but do not guarantee you an award. There are many other factors that the SEC considers, which we’ll discuss below.
Types of Frauds and Violations to Report:
The SEC’s jurisdiction covers the full range of U.S. federal securities law violations. Examples the agency itself highlights include:
- Ponzi and pyramid schemes
- Insider trading
- Manipulation of a security’s price or volume
- Theft or misappropriation of funds
- False or misleading company statements and financial reports
- Fraudulent or unregistered offerings
- Fraud tied to initial coin offerings and cryptocurrencies
For international whistleblowers:
- Bribery of foreign officials
- Payments to foreign officials
These Foreign Corrupt Practices Act (FCPA) violations happen outside the U.S. by definition — and they are among the most common and most valuable tips filed from abroad.
In fact, the SEC openly acknowledges that violations “with elements occurring abroad” can carry heightened law enforcement interest because they’re harder for the agency to detect and prove without a whistleblower’s cooperation.
Avoiding Eligibility “Traps”
A handful of situations can undermine an otherwise strong claim:
- Information covered by attorney-client privilege doesn’t qualify as original information, so disregard this as evidence when self-assessing eligibility.
- If you’re an officer or director who learned of the misconduct from someone else, or through the company’s internal reporting channels, the information may be excluded — though exceptions exist, so don’t write yourself off before speaking with counsel.
- If you reported internally at your company, the clock is running: file with the SEC within 120 days and the agency credits you with your original internal reporting date.
Remember: internal reporting is optional – you can come straight to the SEC. And for many international whistleblowers, particularly those in countries where internal reports leak, that’s the safest path.
Step 2: Understand How Awards Are Calculated
The SEC pays awards ranging from 10% to 30% of the monetary sanctions collected in a successful enforcement action. If there is a joint filing, the SEC will divide the award between each of the whistleblowers, with percentages varying based on various factors.
Every dollar comes from the Investor Protection Fund, which is financed entirely through monetary sanctions paid to the SEC by securities law violators. Nothing is taken from harmed investors — and nothing comes out of taxpayer funds.
How Does the SEC Decide Where You Land in the 10–30% Range?
There is a presumption of the maximum 30% award when the anticipated award is $5 million or less and no negative factors exist — and since most awards fall within this limit, many whistleblowers with strong claims receive the full 30%.
For larger awards, the Commission weighs four factors that can increase your percentage:
- Significance of your information: this is the most critical driver of the award percentage, especially when more than one whistleblower splits an award and the SEC compares whose tip mattered more, and who filed first.
- Assistance you provided: helping staff decipher complex transactions, identifying key witnesses and documents, and supporting the case through litigation is a major factor that can help increase percentages.
- Law enforcement interest: as the SEC puts it, interest may be high for violations “with elements occurring abroad, which may make it more difficult for Commission staff to detect or to gather evidence about without a whistleblower’s cooperation.”
- Participation in internal compliance: reporting internally is never required, but doing so can raise your percentage.
And three factors that can decrease it:
- Unreasonable reporting delay: your award can be reduced if you unreasonably delay reporting the violation to the SEC. Waiting can cost you, so it’s advised that you submit your tip as soon as you can.
- Culpability: whistleblowers who were involved in misconduct can have their award reduced. Note that culpable insiders can still receive awards — just reduced ones. In these types of cases, it’s best to speak with a whistleblower attorney first.
- Interference with internal compliance systems: misleading your compliance department, such as by making false statements, can also reduce the percentage amount under the program.
Related Actions: “Additional” Awards
Under the SEC program, if your information leads to a successful enforcement action by other authorities, you may be eligible for an additional award. The caveat is that you must first qualify for an award under the SEC’s own action.
For international whistleblowers reporting cross-border fraud and violations — where the DOJ frequently runs a criminal case alongside the SEC’s civil one, especially in FCPA matters — related actions can significantly multiply the value of a single tip.
Step 3: Retain Experienced U.S. Counsel
If you are an international whistleblower seeking to file an anonymous tip, you must retain a U.S.-based attorney – this is required by the SEC. In other words, the SEC permits anonymous tip submissions, but to be eligible for an award, an anonymous whistleblower must be represented by an attorney, who submits the tip on the whistleblower’s behalf.
Even if you choose to file using your own name, the agency has a strong reputation for protecting your identity to the fullest extent possible, even under a FOIA request. However, in order to process your tip, your identity may be used in administrative or court proceedings, or it may be revealed in documents, such as when shared with other government or regulatory entities.
Keep in mind, your rights as an international whistleblower under the FCPA exist, but may be hard to enforce if you’re in another country.
Constructive Notice
The moment you retain counsel, a clock you may not know about starts running: you must submit a Form TCR within 30 days of submitting your information to the Commission, or within 30 days of learning of the Form TCR requirement.
You are on “constructive notice” of that requirement the moment you are represented by an attorney. An experienced whistleblower attorney builds the filing around this deadline. An inexperienced one may not know it exists — which is why “U.S. counsel” should really mean “U.S. counsel who practices before the SEC’s whistleblower office.”
International Representation
Intake, document review, drafting, and filing can all be handled remotely by your attorney – you do not need to travel to the U.S. unless your attorney deems it necessary.
Reputable whistleblower firms such as IWA work on a contingency basis, which means no upfront fees. Your attorney gets paid a percentage of an award if you win one, so retaining counsel costs nothing out of pocket regardless of where you reside.
If you’re seeking the world’s best international whistleblower attorney for securities fraud and violations, look no further than IWA. Our team consists of former SEC commissioners and enforcement leaders who have a complete understanding of securities laws. Contact us today for a free and confidential consultation.
Step 4: Gathering Evidence — Lawfully
Under the SEC whistleblower program, international whistleblowers must provide credible, original, and timely information to qualify for an award. The SEC states that the best type of information identifies the individual or organization involved, points to fraudulent transactions, or references non-public materials evidencing fraud.
How you gather evidence is also just as important. Whistleblowers will be immediately disqualified and turned down for representation if it is found that they obtained information by hacking or by obtaining information where access is otherwise restricted. Below is a broader overview of what can make or break your case.
What Evidence Strengthens Your Submission
- Documents showing the mechanics of the scheme
- Names and roles of the people involved
- Dates and amounts of specific transactions
- Location of where additional records can be found
Remember from Step 2 that assistance to staff — helping decipher complex transactions, identifying key witnesses, documents, and other sources of information — can directly increase your award percentage.
What Can Hurt You
- Privileged materials: information subject to the attorney-client privilege is excluded from the definition of original information.
- Unlawful collection: accessing systems or records you have no right to access can expose you to criminal liability in your home country.
- Local data and secrecy laws. Many countries restrict moving personal data or business records across borders — from the EU’s GDPR to bank secrecy and blocking statutes elsewhere.
Protect Your Identity
Below are tips that our whistleblower attorneys and cybersecurity experts have developed over three decades of representing and protecting whistleblowers:
- Use a Personal Device: even when conducting research, you should do so on a non-work device and network. Never use your work email, phone, or company device to contact attorneys or the SEC.
- Avoid Cloud and Email: if the information that you have is on company systems, do not forward it via email or to the cloud. Instead, use a USB thumb drive to transfer information to your personal device.
- Remain Silent: do not tell anyone about the information that you’ve obtained and your choice to submit information to the SEC – silence and patience are the most important qualities of successful whistleblowing.
Make copies of absolutely everything and store them in a safe and secure place. If you have documents in different languages, they can be translated independently or with the assistance of your legal counsel. Avoid translating using AI at all costs.
Step 5: Submitting Your Tip to the SEC
With your evidence in hand, you are now ready to submit an official tip to the SEC using the Tips, Complaints and Referrals (“TCR”) online portal.
Portal filers receive an immediate acknowledgment of their submission along with a confirmation number, and the tip is automatically captured for review. This is especially important to those who are up against a tight filing deadline and is what the SEC prefers.
Remember, anonymous tipsters must retain legal counsel who will file on their behalf.
If you choose to file anonymously, your attorney submits on your behalf and completes the required attorney certification, and you provide your attorney with a completed Form TCR signed under penalty of perjury at the time of submission.
Keep in mind that if you emailed or sent a letter to the SEC prior to submitting the TCR, you have 30 days to submit the official TCR, as required. Failure to meet the 30-day rule can result in an immediate dismissal of your case.
What Happens Next
Every tip is reviewed by the SEC’s Enforcement Division, where the Office of Market Intelligence identifies submissions with high-quality information and assigns the strongest to one of the SEC’s eleven regional offices, a specialty unit, or an Enforcement group at headquarters. Tips related to an existing investigation go to the staff already working the matter.
Once you have made your submission, don’t expect to hear anything back for a while. The SEC conducts investigations confidentially and generally will not comment on whether it has opened an investigation or the status of one. The agency itself acknowledges this can be frustrating, but it protects the investigation and everyone involved, including you.
No news does not mean your tip went nowhere.
If you come across new information later, you can supplement your tip through the portal, referencing your original TCR submission number — or directly to the Enforcement staff if you’re already working with them. Strong cases are often built through exactly this kind of ongoing cooperation, which (per Step 2) is also what pushes award percentages upward.
Step 6: Monitor for a Covered Action and Apply for Your Award
It’s important to know from the start that the SEC does not automatically pay the award when the case succeeds.
When an SEC enforcement action results in sanctions over $1 million, the agency posts a Notice of Covered Action (“NoCA”) on its website. These are generally posted at the end of each month, so those who believe their information was used for the investigation can apply.
Notice of Covered Action (“NoCA”) Website: https://www.sec.gov/enforcement-litigation/whistleblower-program/whistleblower-program-notices-covered-action
You can sign up for email alerts that fire every time the NoCA list updates — but in practice, this is a job your attorney handles. A firm tracking your matter monitors the postings, matches them against your tip, and files on time. For a whistleblower nine time zones from Washington, that monitoring is one of the most concrete things U.S. counsel does for you.
The 90-Day Deadline Is Unforgiving
Once the relevant NoCA is posted, you must submit Form WB-APP to the Office of the Whistleblower within 90 calendar days. You cannot miss this, as there is no second chance to claim the award. It’s also important to know that the application is more than a formality. The SEC expects you to make your case within it:
- Correct identification: identify the specific Covered Action — name and notice number — or your application may be deemed deficient.
- Address factual issues head-on: if you’re an officer or director, explain why the exclusion doesn’t apply; if you delayed reporting, explain the circumstances; if you had any role in the misconduct, address your involvement fully.
- Submit everything within the window: after this point, supplemental submissions are excluded from consideration — the 90 days is your one shot to put in everything relevant to your claim.
For related actions, you claim on the same Form WB-APP if a final order has already been entered – if the related action concludes later, you file within 90 days of its final order.
What Happens After Submitting Form WB-APP
The Claims Review Staff issues a preliminary determination recommending that your claim be granted or denied — and if granted, at what percentage. Be sure to review the positive and negative award factors in Step 2 above.
If you believe that their decision was incorrect, you can request reconsideration within 60 days. If the Commission ultimately denies your claim, you may appeal to a U.S. Court of Appeals within 30 days; but if you’re granted an award between 10% and 30% determined under the proper factors, that decision is not appealable.
You will not receive status updates while your application is pending, and claims may not be evaluated until all appeals are resolved. This can take some time, so avoid filing repeated or frivolous award applications — submitting three or more frivolous claims can result in a permanent bar from the program.
Apply when your tip genuinely connects to the action — and let counsel make that judgment with you.
How Long Does the Process Take?
The SEC publishes no official timeline. However, the typical timeline that we’ve encountered runs through three stages, each with its own clock:
- Investigation (often 2–4 years): after your tip is filed, the SEC investigates confidentially and won’t comment on its status. Silence is normal.
- Enforcement and the NoCA: if the action succeeds with sanctions over $1 million, the Notice of Covered Action posts — and your 90-day application window opens.
- Award review (1–2+ years): claims may not even be evaluated until all appeals in the underlying case are resolved, then move through preliminary determination, any reconsideration, and a final order before payment.
End to end, four to six years from tip to payment is common — sometimes longer, occasionally faster when a tip lands in an active investigation.
Contact IWA SEC Whistleblower Attorneys Today!
If you have information about securities fraud touching U.S. markets, you don’t have to navigate the SEC’s process — or weigh the risks of coming forward from abroad — on your own.
A free, confidential consultation makes sense if you are:
- A non-U.S. citizen or foreign resident with evidence of securities fraud, foreign bribery (FCPA), or other violations involving a U.S.-listed or SEC-registered company
- An employee, former employee, executive, or compliance professional unsure whether eligibility exclusions apply to you
- Someone who has already reported internally — and needs to act within the 120-day window
- Considering filing anonymously, which requires U.S. counsel under SEC rules
Everything you share is protected by attorney-client privilege, whether or not you ever file.
