Individuals anywhere in the world with information about fraud or manipulation in the commodities and derivatives markets \u2014 or any violation of the U.S. Commodity Exchange Act \u2014 are permitted to blow the whistle to the U.S. Commodity Futures Trading Commission (CFTC) and potentially qualify for an award.<\/p>\n\n\n\n
These awards pay between 10% and 30% of the monetary sanctions collected when original information leads to a successful enforcement action resulting in sanctions over $1 million.<\/p>\n\n\n\n
The CFTC Whistleblower Program<\/a> was created by the Dodd-Frank Act after the 2008 global financial crisis. Section 748 of that law added a new Section 23 \u2014 \u201cCommodity Whistleblower Incentives and Protection\u201d<\/a> \u2014 to the Commodity Exchange Act.<\/p>\n\n\n\n Since the program issued its first award in 2014, the CFTC has granted 55 award orders totaling more than $390 million<\/a> to whistleblowers. These awards are not reserved for U.S. nationals \u2014 the CFTC has publicly confirmed paying whistleblowers based outside the United States<\/a>, consistent with a program built to reward original information from anywhere in the world.<\/p>\n\n\n\n Those awards are tied to enforcement actions that have collected over $3.2 billion<\/strong> in monetary sanctions. Every dollar of every award is paid from the CFTC Customer Protection Fund<\/a>, which is financed entirely by the sanctions that violators pay \u2014 never from the pockets of harmed customers, and never from taxpayers.<\/p>\n\n\n\n The CFTC program is global by design.<\/p>\n\n\n\n In FY2025 alone the agency received 1,697 tips<\/a>, and the Whistleblower Office reports that submissions came from many different countries \u2014 with the most originating from the United States, Canada, and the United Kingdom. You do not need to be a U.S. citizen, live in the United States, or work at the company you\u2019re reporting to take part.<\/p>\n\n\n\n Continue reading to learn how international whistleblowers can report commodities and derivatives fraud to the CFTC, and what to expect before, during, and after filing.<\/strong><\/p>\n\n\n\n Before taking any further steps, keep the information that you have to yourself until you\u2019ve retained counsel. This matters most if you live in a country with weak whistleblower protections or a history of retaliation against people who expose wrongdoing.<\/p>\n\n\n\n Below are the building blocks of a strong CFTC case:<\/strong><\/p>\n\n\n\n The largest award in program history reached nearly $200 million in 2021<\/a> \u2014 and notably, that case turned on transnational cooperation, with related actions brought by both a U.S. federal regulator and a foreign regulator.<\/p>\n\n\n\n International Whistleblower Advocates\u2019 network includes attorneys who have handled significant international whistleblower matters and advocates who helped shape the modern whistleblower-reward model.<\/p>\n\n\n\n For international whistleblowers, experienced U.S. counsel is critical. Claiming an award anonymously requires a U.S.-based attorney who can help you prepare a well-built submission aimed at the highest possible award percentage within the 10\u201330% range.<\/p>\n\n\n\n If you\u2019d like to come forward and find the best path, we suggest contacting our international commodities fraud attorneys for a free and confidential consultation.<\/strong><\/p>\n\n\n\n Confirm that your information meets the CFTC\u2019s eligibility criteria<\/a>. If you\u2019re unsure, speak with an experienced international whistleblower attorney<\/a> first.<\/p>\n\n\n\n The CFTC allows anyone, anywhere in the world, to submit a tip. You do not need to be a U.S. citizen, live in the U.S., or work at the company you\u2019re reporting. The CFTC receives tips from around the globe and treats foreign sources no differently than domestic ones.<\/p>\n\n\n\n To be eligible for an award, your information must meet the following criteria:<\/p>\n\n\n\n These are the baseline requirements; they don\u2019t guarantee an award. The CFTC weighs a number of other factors, discussed below.<\/p>\n\n\n\n Types of Violations to Report<\/strong><\/p>\n\n\n\n The CFTC\u2019s jurisdiction covers the full range of Commodity Exchange Act violations across the U.S. derivatives markets \u2014 futures, options, and swaps \u2014 as well as fraud or manipulation in the sale of any commodity in interstate commerce, including certain digital assets.<\/p>\n\n\n\n To help the public spot reportable conduct, the CFTC\u2019s Whistleblower Office publishes Whistleblower Alerts<\/a> on priority areas, including:<\/p>\n\n\n\n Many of these are inherently cross-border. Benchmark manipulation is a clear example: the CFTC has brought major actions against global banks for attempting to rig foreign-exchange and interest-rate benchmarks, including a 2014 order against five banks totaling more than $1.4 billion<\/a> and an $800 million order against Deutsche Bank<\/a> for manipulation and false reporting of LIBOR and Euribor.<\/p>\n\n\n\n A few situations can undermine an otherwise strong claim:<\/p>\n\n\n\n Remember: internal reporting is optional \u2014 you can come straight to the CFTC at any time. For many international whistleblowers, particularly in countries where internal reports leak, that is the safer path.<\/p>\n\n\n\n For whistleblowers outside the United States, one of the most valuable and least understood avenues is foreign corruption that touches the commodities and derivatives markets. The CFTC has made clear it will pursue this conduct, issuing a dedicated Whistleblower Alert on foreign corrupt practices<\/a> and an Enforcement Advisory<\/a> signaling its expanded focus on the issue.<\/p>\n\n\n\n The CFTC does not enforce the Foreign Corrupt Practices Act (FCPA) the way the SEC does. Instead, it pursues corruption as a violation of the Commodity Exchange Act<\/strong> when that corruption affects the markets it regulates. According to the CFTC\u2019s own alert, reportable misconduct may include:<\/p>\n\n\n\n This is a different legal theory than the SEC\u2019s books-and-records and accounting-controls approach to the FCPA, and it can reach conduct the SEC\u2019s framework might not. For a deeper background on the law itself, see our\u00a0complete FCPA FAQ<\/a>\u00a0and our explainer on\u00a0your rights as an international whistleblower under the FCPA<\/a>.<\/p>\n\n\n\n Foreign corruption, by definition, usually happens outside the United States. That makes it exactly the kind of misconduct the CFTC struggles to detect on its own \u2014 and exactly where an insider\u2019s information carries the most weight. You do not need to be an employee or trader to qualify: victims of fraud and other market participants who observe the misconduct can be whistleblowers too.<\/p>\n\n\n\n There is also a structural reason this avenue can be so valuable to international whistleblowers: Related Actions<\/strong>. As explained in Step 2, when your information also leads to a successful case by another authority \u2014 including a foreign futures authority or the U.S. Department of Justice, which frequently runs parallel criminal cases in corruption matters \u2014 a single tip can produce awards across multiple actions. The record nearly-$200 million award<\/a> was built on precisely this cross-border structure, with related actions by both a U.S. federal regulator and a foreign regulator.<\/p>\n\n\n\n The CFTC pays awards ranging from 10% to 30% of the monetary sanctions collected in a successful enforcement action. If multiple whistleblowers are granted awards in the same action, the total is still capped within that 10\u201330% band and divided among them.<\/p>\n\n\n\n Every dollar comes from the CFTC Customer Protection Fund<\/a>, financed entirely through sanctions paid by violators of the Commodity Exchange Act. Nothing is taken from harmed customers, and nothing comes from taxpayer funds.<\/p>\n\n\n\n When setting an award within the 10\u201330% range, the CFTC may increase the percentage<\/a> based on:<\/p>\n\n\n\n The CFTC may reduce the percentage<\/a> based on:<\/p>\n\n\n\n If you intend to claim your award anonymously, you must be represented by a U.S.-based attorney<\/a>. This is the central nuance of the program: you may submit a tip anonymously with or without a lawyer, but to claim an award anonymously, counsel is mandatory, and your identity must be verified to the CFTC\u2019s satisfaction before any award is paid. (For more on this distinction, see our FAQ on anonymous versus confidential whistleblowing<\/a>.)<\/p>\n\n\n\n Even if you file under your own name, the CFTC is committed to protecting your identity. They treats information learned during an investigation \u2014 including the identity of sources \u2014 as non-public and confidential, and it will not disclose identifying information in response to a Freedom of Information Act request.<\/p>\n\n\n\n There are limits: in an administrative or court proceeding the CFTC may be required to produce information that reveals your identity, and it may share information, subject to confidentiality requirements, with other governmental or regulatory entities.<\/p>\n\n\n\n Keep in mind that your protections as an international whistleblower<\/a> under U.S. law exist but are harder to enforce from abroad \u2014 another reason experienced counsel matters.<\/p>\n\n\n\n Intake, document review, drafting, and filing can all be handled remotely by your attorney. You do not need to travel to the United States unless your attorney determines it\u2019s necessary.<\/p>\n\n\n\n Reputable whistleblower firms almost always work on a contingency basis, meaning no upfront fees \u2014 your attorney is paid a percentage of an award only if you win one. Retaining counsel therefore costs nothing out of pocket, regardless of where you live.<\/p>\n\n\n\n To qualify for an award, an international whistleblower must provide credible, original, and timely information. How you gather that information matters just as much as what it shows.<\/p>\n\n\n\n Whistleblowers can be disqualified \u2014 and turned down for representation \u2014 if they obtained information by hacking or by accessing materials they had no right to access.<\/p>\n\n\n\n Below is an overview of what helps and what hurts.<\/p>\n\n\n\n Remember from Step 2 that helping staff understand complex transactions and pointing them to key witnesses and documents can potentially raise your award percentage.<\/p>\n\n\n\n Below are practices developed over decades of representing and protecting whistleblowers:<\/p>\n\n\n\n Make copies of everything and store them somewhere safe and secure. If you have documents in other languages, have them translated independently or with your legal counsel. Avoid translating sensitive documents using AI tools.<\/strong><\/p>\n\n\n\n With your evidence in hand, you\u2019re ready to submit an official tip using the CFTC\u2019s Form TCR (Tip, Complaint, or Referral)<\/a>. The Whistleblower Office strongly encourages filing through its online portal<\/a>; a Form TCR can also be submitted by mail or fax, but only one method is needed.<\/p>\n\n\n\n After you file, the Whistleblower Office will confirm in writing that your Form TCR was received and give you a confirmation number \u2014 keep it. If you don\u2019t receive written confirmation within 14 days, the office asks that you email it directly.<\/p>\n\n\n\n Remember the central rule: anyone can submit a tip anonymously, but claiming an award anonymously requires an attorney who files on your behalf.<\/p>\n\n\n\n The CFTC reviews every tip. Your information could prompt the Commission to open a new investigation, reopen a closed one, pursue a new line of inquiry in an ongoing matter, or significantly contribute to an enforcement action already underway.<\/p>\n\n\n\n Don\u2019t expect to hear much after you file.<\/p>\n\n\n\n The CFTC conducts investigations confidentially and generally will not tell you whether it has opened an investigation or where one stands. The agency acknowledges this can be frustrating, but the silence protects the investigation and everyone involved \u2014 including you.<\/p>\n\n\n\n No news does not mean your tip went nowhere.<\/strong><\/p>\n\n\n\n In FY2025, roughly a third of the CFTC\u2019s enforcement leads originated from whistleblower tips.<\/p>\n\n\n\n If you later obtain additional information, you can supplement your tip by email \u2014 just reference your original confirmation number. Ongoing cooperation is often how the strongest cases are built, and (per Step 2) it can push award percentages upward.<\/p>\n\n\n\n It\u2019s important to understand from the start that the CFTC does not automatically pay you when a case succeeds. You have to apply.<\/p>\n\n\n\n When the CFTC obtains a judgment or settlement imposing more than $1 million in monetary sanctions, the Whistleblower Office posts a Notice of Covered Action (NCA)<\/a> on its website.<\/p>\n\n\n\n The CFTC does not contact whistleblowers individually about these postings, so you\u2019ll need to monitor the page \u2014 or subscribe to email alerts<\/a> that fire when a new NCA is posted.<\/p>\n\n\n\n In practice, this monitoring is one of the most concrete things U.S. counsel does for a whistleblower nine time zones from Washington.<\/p>\n\n\n\nBefore You Begin: CFTC Whistleblower Self-Assessment<\/h2>\n\n\n\n
\n
Attorneys With Inside Knowledge<\/h3>\n\n\n\n
Step 1: Verifying Eligibility<\/h2>\n\n\n\n
\n
\n
Avoiding Eligibility \u201cTraps\u201d<\/h3>\n\n\n\n
\n
Foreign Corruption and the FCPA: A Major Avenue for International Whistleblowers<\/h2>\n\n\n\n
How the CFTC Treats Foreign Corruption<\/h3>\n\n\n\n
\n
Why This Matters Most to Whistleblowers Abroad<\/h3>\n\n\n\n
Step 2: Understand How Awards Are Calculated<\/h2>\n\n\n\n
What Can Increase Your Percentage<\/h3>\n\n\n\n
\n
What Can Decrease It<\/h3>\n\n\n\n
\n
Step 3: Retain Experienced U.S. Counsel<\/h2>\n\n\n\n
International Representation<\/h3>\n\n\n\n
Step 4: Gathering Evidence \u2014 Lawfully<\/h2>\n\n\n\n
What Strengthens Your Submission<\/h3>\n\n\n\n
\n
What Can Hurt You<\/h3>\n\n\n\n
\n
Protect Your Identity<\/h3>\n\n\n\n
\n
Step 5: Submitting Your Tip to the CFTC<\/h2>\n\n\n\n
What Happens Next<\/h3>\n\n\n\n
Step 6: Monitor for a Covered Action and Apply for Your Award<\/h2>\n\n\n\n
The 90-Day Deadline Is Unforgiving<\/h3>\n\n\n\n