The Commodity Futures Trading Commission awarded approximately $200 million to a single whistleblower earlier this month based on the individual’s “significant contribution” to the success of a CFTC action and two Related Actions by other enforcement agencies. This is not just the largest award of the CFTC to date under its Dodd-Frank whistleblower program, but larger than any award ever made to a single whistleblower by the SEC under Dodd-Frank. Although the Commission maintains whistleblower confidentiality and its award decision is heavily redacted, the Wall Street Journal reports that the whistleblower tip involved alleged LIBOR manipulation at Deutsche Bank.

Several key points about this award decision:

• The whistleblower’s request for an award was initially denied. The whistleblower’s counsel then submitted a request for reconsideration, which included an affidavit from a federal official (likely from the Department of Justice, based on the WSJ coverage), explaining how the whistleblower’s information directly contributed to the successful outcome. The CFTC then reconsidered all of the evidence and reversed course, granting the award.
• Federal investigations were already underway when the whistleblower came forward. In addition, the individual did not provide “direct evidence” of the violations themselves. Nevertheless, according to the CFTC, the whistleblower’s information “led directly to evidence” by increasing regulators’ understanding of a key issue, which in...

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