Guidance Through Form TCR, Investigative Stages, Monitoring,
WB-APP Submissions, and Award Appeals
Freiberger Haber LLP guides whistleblowers through every stage of the CFTC Whistleblower Program, including preparing and submitting Form TCR, navigating investigative stages, monitoring enforcement developments, filing WB-APP award applications, and handling appeals—while ensuring confidentiality and strategic protection at every step.
The CFTC Whistleblower Program empowers individuals in the U.S. and abroad to report commodities fraud and violations of the Commodity Exchange Act. Eligible whistleblowers can receive 10%–30% of monetary sanctions the CFTC collects when their information leads to a successful enforcement action or a related action.
At Freiberger Haber, we help clients come forward anonymously and effectively—protecting the integrity of the commodities and derivatives markets, holding wrongdoers accountable, and potentially securing substantial financial awards.
Market manipulation
Digital asset and crypto-derivatives misconduct
Misuse of customer funds
Spoofing and manipulative
trading schemes
FCM, IB, CTA,
and CPO violations
Misrepresentations in swaps and derivatives markets
Fraud affecting futures,
swaps, or options
Benchmark manipulation (e.g., ISDAFIX, LIBOR-related conduct)
Protecting Those Who Report Commodities Fraud
The CFTC Whistleblower Program, created under the Dodd-Frank Act in 2010, encourages individuals to report violations of the Commodity Exchange Act by offering substantial monetary awards, strong confidentiality, and federal anti-retaliation protections.
Whistleblowers—domestic or foreign—may submit information relating to commodities fraud, spoofing, market manipulation, crypto-related derivatives misconduct, illicit trading practices, and other CEA violations.
How We Approach CFTC Whistleblower Matters
The CFTC provides some of the strongest protections in federal law:
Anonymity: A whistleblower may remain anonymous if represented by counsel.
Confidentiality: The CFTC does not disclose identifying information except when required in limited legal circumstances.
Anti-Retaliation: Employers are prohibited from firing, demoting, suspending, or otherwise discriminating against whistleblowers. Remedies include reinstatement, back pay, and attorney’s fees.
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U.S. and non-U.S. individuals
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Employees, executives, and board members
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Traders, brokers, and market professionals
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IT and cybersecurity personnel
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Digital-asset experts
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Competitors, customers, and market participants
Frequently Asked Questions
Any individual, or group of individuals, may be eligible. There are no restrictions based on citizenship, profession, or seniority. Whistleblowers often include:
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Employees
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Consultants and contractors
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Traders and analysts
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Compliance personnel (with exceptions, noted below)
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Executives and board members
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Technology professionals
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Industry competitors and market participants
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Individuals with digital-asset market expertise
Congress designed the program to encourage anyone with valuable insider or analytical insights to report wrongdoing.
