Using a proprietary dataset, Dave Jochnowitz, Steven Singer, and Mona Birjandi analyze trends in the Securities and Exchange Commission’s whistleblower program. They find that sanctions have concentrated in a select few violation categories, raising the possibility that the program is structurally guiding enforcers to focus on certain violation types to the neglect of others.
The 2010 Dodd-Frank Wall Street Reform and Consumer Protection Act launched in 2011 a whistleblower program housed under the Securities and Exchange Commission to detect and help punish securities law violations, including bribery and fraud. From its launch through 2024, the program paid out more than $2.2 billion in awards to tipsters and helped recover billions from wrongdoers. On volume and monetary recovery alone, the program has been a success. However, our analysis of the whistleblower program found that it does not simply encourage enforcement, but appears to systematically skew it, concentrating regulatory attention in the narrow band of violation categories easiest to detect. The concern is that the program is failing to detect the full spectrum of violation types and is instead stuck in a reinforcement loop that rewards the SEC’s existing strengths while allowing harder-to-detect misconduct to recede from view.
How we conducted our analysis
We built a dataset of more than 5,000 SEC enforcement documents (across approximately 3,149 unique enforcement actions) from 2011–2025. These documents...
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