Introduction
Individuals anywhere in the world with information about fraud or manipulation in the commodities and derivatives markets — or any violation of the U.S. Commodity Exchange Act — are permitted to blow the whistle to the U.S. Commodity Futures Trading Commission (CFTC) and potentially qualify for an award.
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.
The CFTC Whistleblower Program was created by the Dodd-Frank Act after the 2008 global financial crisis. Section 748 of that law added a new Section 23 — “Commodity Whistleblower Incentives and Protection” — to the Commodity Exchange Act.
Since the program issued its first award in 2014, the CFTC has granted 55 award orders totaling more than $390 million to whistleblowers. These awards are not reserved for U.S. nationals — the CFTC has publicly confirmed paying whistleblowers based outside the United States, consistent with a program built to reward original information from anywhere in the world.
Those awards are tied to enforcement actions that have collected over $3.2 billion in monetary sanctions. Every dollar of every award is paid from the CFTC Customer Protection Fund, which is financed entirely by the sanctions that violators pay — never from the pockets of harmed customers, and never from taxpayers.
The CFTC program is global by design.
In FY2025 alone the agency received 1,697 tips, and the Whistleblower Office reports that submissions came from many different countries — 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’re reporting to take part.
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.
Before You Begin: CFTC Whistleblower Self-Assessment
Before taking any further steps, keep the information that you have to yourself until you’ve 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.
Below are the building blocks of a strong CFTC case:
- Specific, credible, and timely information about a possible violation of the U.S. Commodity Exchange Act.
- Confidence that you’re reporting voluntarily — before the CFTC or another authority sends a request, inquiry, or demand about the matter to you.
- Original information from your own independent knowledge or analysis, not something the CFTC already knows.
- A submission made directly to the CFTC on Form TCR or through its online portal — reporting only to another agency or the media does not qualify.
- Information that leads to a successful enforcement action with monetary sanctions over $1 million.
- U.S. counsel if you intend to claim an award anonymously — required under the Whistleblower Rules, not optional.
- Awareness of the 180-day window to reach the CFTC if you first reported internally.
- Patience for a multi-year path from tip to investigation to award.
The largest award in program history reached nearly $200 million in 2021 — and notably, that case turned on transnational cooperation, with related actions brought by both a U.S. federal regulator and a foreign regulator.
Attorneys With Inside Knowledge
International Whistleblower Advocates’ network includes attorneys who have handled significant international whistleblower matters and advocates who helped shape the modern whistleblower-reward model.
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 10–30% range.
If you’d like to come forward and find the best path, we suggest contacting our international commodities fraud attorneys for a free and confidential consultation.
Step 1: Verifying Eligibility
Confirm that your information meets the CFTC’s eligibility criteria. If you’re unsure, speak with an experienced international whistleblower attorney first.
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’re reporting. The CFTC receives tips from around the globe 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 before the CFTC — or Congress, another regulator, or a self-regulatory organization such as the National Futures Association — sends a request, inquiry, or demand about the same matter to you. If you provided the information to one of those bodies before receiving any such request, your submission to the CFTC still counts as voluntary.
- Original: information derived from your independent knowledge (facts not generally known or public) or your own independent analysis (your evaluation of information that may be public but reveals something not generally known) — and not already known to the CFTC.
- Submitted to the CFTC: filing a Form TCR, or a submission through the CFTC’s online portal, preserves your award rights. Reporting only to your local regulator or the press does not.
- Over the $1 million threshold: your tip must lead to — or significantly contribute to — a successful enforcement action in which monetary sanctions exceed $1 million.
- An individual, alone or jointly: you can file alone or with others, but a company or organization cannot be a whistleblower.
These are the baseline requirements; they don’t guarantee an award. The CFTC weighs a number of other factors, discussed below.
Types of Violations to Report
The CFTC’s jurisdiction covers the full range of Commodity Exchange Act violations across the U.S. derivatives markets — futures, options, and swaps — as well as fraud or manipulation in the sale of any commodity in interstate commerce, including certain digital assets.
To help the public spot reportable conduct, the CFTC’s Whistleblower Office publishes Whistleblower Alerts on priority areas, including:
- Spoofing and other disruptive trading in the commodities and derivatives markets
- Foreign corrupt practices connected to the markets the CFTC oversees
- Bank Secrecy Act failures, including deficient anti-money-laundering (AML) and suspicious-activity-report programs
- Insider trading or other improper use of confidential information
- Digital asset and virtual currency fraud, including “pump-and-dump” schemes and unregistered platforms
- Romance investment (“pig butchering”) frauds that steer victims into fake crypto or forex platforms
- Fraud and manipulation in the carbon markets
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 and an $800 million order against Deutsche Bank for manipulation and false reporting of LIBOR and Euribor.
Avoiding Eligibility “Traps”
A few situations can undermine an otherwise strong claim:
- Information protected by the attorney-client privilege generally does not count as original information, so set it aside when assessing your own eligibility.
- Certain people are excluded — for example, some government and self-regulatory personnel, employees of foreign regulatory authorities, and anyone convicted of a crime connected to the conduct at issue. Officers, directors, and partners who learned of the misconduct through the company’s internal compliance processes may also be excluded, though exceptions exist, which can be better explained by experienced counsel.
- If you reported internally at your company first, the clock is running: reach the CFTC within 180 days and the agency will treat your “place in line” as the date you reported internally.
Remember: internal reporting is optional — 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.
Foreign Corruption and the FCPA: A Major Avenue for International Whistleblowers
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 and an Enforcement Advisory signaling its expanded focus on the issue.
How the CFTC Treats Foreign Corruption
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 when that corruption affects the markets it regulates. According to the CFTC’s own alert, reportable misconduct may include:
- Corrupt practices that alter prices in commodity markets that, in turn, drive U.S. derivatives prices;
- Bribes used to secure business in connection with regulated activities — like trading, advising, or dealing in swaps or derivatives — paid out of funds that investors believed were being used to invest; and
- Corrupt practices used to manipulate benchmarks that serve as the basis for derivatives contracts, where prices that are the product of corruption are then falsely reported to those benchmarks.
This is a different legal theory than the SEC’s books-and-records and accounting-controls approach to the FCPA, and it can reach conduct the SEC’s framework might not. For a deeper background on the law itself, see our complete FCPA FAQ and our explainer on your rights as an international whistleblower under the FCPA.
Why This Matters Most to Whistleblowers Abroad
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 — and exactly where an insider’s 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.
There is also a structural reason this avenue can be so valuable to international whistleblowers: Related Actions. As explained in Step 2, when your information also leads to a successful case by another authority — including a foreign futures authority or the U.S. Department of Justice, which frequently runs parallel criminal cases in corruption matters — a single tip can produce awards across multiple actions. The record nearly-$200 million award was built on precisely this cross-border structure, with related actions by both a U.S. federal regulator and a foreign regulator.
Step 2: Understand How Awards Are Calculated
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 10–30% band and divided among them.
Every dollar comes from the CFTC Customer Protection Fund, financed entirely through sanctions paid by violators of the Commodity Exchange Act. Nothing is taken from harmed customers, and nothing comes from taxpayer funds.
What Can Increase Your Percentage
When setting an award within the 10–30% range, the CFTC may increase the percentage based on:
- The significance of your information to the success of the action: often the single most important driver, especially when more than one whistleblower is involved and the CFTC compares whose information mattered more and who came forward first.
- The assistance you provided: helping staff understand complex transactions, identifying key witnesses and documents, and supporting the case through its conclusion.
- Law enforcement interest: the CFTC’s interest in deterring violations by rewarding whistleblowers whose information leads to successful enforcement.
- Your participation in internal compliance: reporting internally is never required, but doing so can raise your percentage.
What Can Decrease It
The CFTC may reduce the percentage based on:
- Culpability: whistleblowers who were involved in the misconduct can have awards reduced. Culpable insiders can still receive awards, just smaller ones; in these situations, it’s best to speak with a whistleblower attorney first.
- Unreasonable reporting delay: waiting too long to report can cost you, so submit your tip as soon as you reasonably can.
- Interference with internal compliance: undermining or making false statements to your company’s compliance systems can reduce the award.
Step 3: Retain Experienced U.S. Counsel
If you intend to claim your award anonymously, you must be represented by a U.S.-based attorney. 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’s satisfaction before any award is paid. (For more on this distinction, see our FAQ on anonymous versus confidential whistleblowing.)
Even if you file under your own name, the CFTC is committed to protecting your identity. They treats information learned during an investigation — including the identity of sources — as non-public and confidential, and it will not disclose identifying information in response to a Freedom of Information Act request.
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.
Keep in mind that your protections as an international whistleblower under U.S. law exist but are harder to enforce from abroad — another reason experienced counsel matters.
International Representation
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’s necessary.
Reputable whistleblower firms almost always work on a contingency basis, meaning no upfront fees — 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.
Step 4: Gathering Evidence — Lawfully
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.
Whistleblowers can be disqualified — and turned down for representation — if they obtained information by hacking or by accessing materials they had no right to access.
Below is an overview of what helps and what hurts.
What Strengthens Your Submission
- Documents showing the mechanics of the scheme
- Names and roles of the people involved
- Dates and amounts of specific transactions
- The location of additional records
Remember from Step 2 that helping staff understand complex transactions and pointing them to key witnesses and documents can potentially raise your award percentage.
What Can Hurt You
- Privileged materials: information subject to the attorney-client privilege is generally 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 practices developed over decades of representing and protecting whistleblowers:
- Use a personal device: do your research on a non-work device and network. Never use your work email, phone, or company device to contact attorneys or the CFTC.
- Avoid cloud and email: if the information is on company systems, don’t forward it to email or the cloud. Where lawful, use a personal storage device to keep your own copies.
- Remain silent: don’t tell anyone what you’ve found or that you plan to report it. Silence and patience are the most important qualities of successful whistleblowing.
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.
Step 5: Submitting Your Tip to the CFTC
With your evidence in hand, you’re ready to submit an official tip using the CFTC’s Form TCR (Tip, Complaint, or Referral). The Whistleblower Office strongly encourages filing through its online portal; a Form TCR can also be submitted by mail or fax, but only one method is needed.
After you file, the Whistleblower Office will confirm in writing that your Form TCR was received and give you a confirmation number — keep it. If you don’t receive written confirmation within 14 days, the office asks that you email it directly.
Remember the central rule: anyone can submit a tip anonymously, but claiming an award anonymously requires an attorney who files on your behalf.
What Happens Next
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.
Don’t expect to hear much after you file.
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 — including you.
No news does not mean your tip went nowhere.
In FY2025, roughly a third of the CFTC’s enforcement leads originated from whistleblower tips.
If you later obtain additional information, you can supplement your tip by email — 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.
Step 6: Monitor for a Covered Action and Apply for Your Award
It’s important to understand from the start that the CFTC does not automatically pay you when a case succeeds. You have to apply.
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) on its website.
The CFTC does not contact whistleblowers individually about these postings, so you’ll need to monitor the page — or subscribe to email alerts that fire when a new NCA is posted.
In practice, this monitoring is one of the most concrete things U.S. counsel does for a whistleblower nine time zones from Washington.
The 90-Day Deadline Is Unforgiving
Once the relevant NCA is posted, you must submit Form WB-APP within 90 calendar days. There is no second chance to claim the award. For Related Actions, you apply within 90 days of the judgment or order in that action; the CFTC does not post notices for Related Actions, so you must monitor other authorities’ cases on your own.
The application is more than a formality — it’s where you make your case. Address any factual issues directly: if an exclusion might apply to you, explain why it doesn’t; if you delayed reporting, explain the circumstances; if you had any role in the misconduct, address it fully.
What Happens After You Apply
Since the rules were amended in 2017, the CFTC’s award-review process closely mirrors the SEC’s. The Claims Review Staff issues a Preliminary Determination recommending that your claim be granted or denied — and, if granted, at what percentage. You have an opportunity to view the record and contest a preliminary denial before the Commission issues a Final Determination.
If sanctions are collected only in part, you still receive your determined percentage of what is actually collected, and you remain eligible for the same percentage of any amounts the CFTC collects later. Awards are paid from the Customer Protection Fund and do not reduce the money owed to harmed customers.
How Long Does the Process Take?
The CFTC publishes no official timeline, but in practice the path runs through three stages, each with its own clock:
- Investigation (often several years): after your tip is filed, the CFTC investigates confidentially and won’t comment on its status. Silence is normal.
- Enforcement and the NCA: if the action succeeds with sanctions over $1 million, the Notice of Covered Action posts — and your 90-day application window opens.
- Award review: your application moves through a Preliminary Determination, any challenge, and a Final Order before payment, and may not be resolved until related proceedings conclude.
End to end, several years from tip to payment is common — sometimes longer, occasionally faster when a tip lands in an active investigation.
Contact IWA’s CFTC Whistleblower Attorneys Today
If you have information about fraud or manipulation touching the U.S. commodities and derivatives markets, you don’t have to navigate the CFTC’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 commodities or derivatives fraud, benchmark manipulation, spoofing, or foreign corruption affecting the markets the CFTC regulates
- An employee, former employee, executive, trader, or compliance professional unsure whether an eligibility exclusion applies to you
- Someone who has already reported internally — and needs to act within the 180-day window
- Considering claiming an award anonymously, which requires U.S. counsel under the Whistleblower Rules
Everything you share is protected by attorney-client privilege, whether or not you ever file.
