CFTC Form WB-APP and Notices of Covered Action: The Tip Was Only the Start

A CFTC whistleblower award application uses Form WB-APP to seek a reward after an enforcement action. It is separate from the original tip on Form TCR. You may already have explained a trading position, identified a reporting failure or helped investigators understand the firm’s records. The award application connects that contribution to the action the Commodity Futures Trading Commission brought. We work with you and CFTC whistleblower counsel to make that connection clear.

How Do I Apply for an Award?

Form WB-APP is the Commodity Futures Trading Commission’s award application. We assess your contribution and the evidence supporting the claim under the agency’s award guidance.

The original account may explain what happened on a trading desk or inside a reporting system. The award claim also needs to show how the information helped the agency’s work. We examine the information, its delivery to the Commission and its use in the investigation together.

CFTC whistleblower eligibility turns on voluntary, original information that leads to successful enforcement. A contribution can start an investigation, redirect it or significantly assist one already underway.

CFTC Notice of Covered Action and the 90-Day Deadline

The CFTC Notice of Covered Action ordinarily starts a 90-day deadline for the Commission to receive Form WB-APP and its attachments. The original tip and the notice belong to different stages of the CFTC whistleblower award timeline. The Commodity Futures Trading Commission posts the notice after a final judgment or order, alone or together with earlier orders in the action, imposes more than $1 million in monetary sanctions.

The Commission uses a public notice system, rather than individually notifying prospective applicants. Connecting the relevant notice to your submissions is part of our work on the award claim.

UBS Financial Services Shows What a Notice Means

UBS Financial Services admitted failures to configure and administer anti-money-laundering monitoring for foreign-currency wire transfers. Its July 31, 2026 CFTC order imposed an $8 million civil penalty. This was a futures commission merchant’s supervision failure, involving the setup and operation of the system watching those transfers.

The UBS Financial Services notice, published August 26, 2026, listed November 24, 2026 as the award-application deadline. The enforcement order and the notice were distinct events, with different dates and different jobs.

What the Award Application Connects

A completed Form WB-APP and its supporting material connect the original information, the relevant enforcement action and the whistleblower’s contribution. A useful account follows what the person supplied and what that information helped investigators establish.

The submission record matters here: the content sent to the Commission, attachments and dates. Those materials let us distinguish what the whistleblower knew from what the agency received, and place the assistance alongside the investigation.

For a market insider, explanation can be as important as the document being explained. The person who understands the trade can explain its significance. An award decision discussed below shows that such an explanation helped investigators reach direct evidence and obtain admissions. We look for the specific connection: what information advanced the investigation, what it explained and how the award claim can demonstrate that contribution.

May I Apply for an Award Anonymously?

We work through anonymous CFTC whistleblower claims with you and CFTC whistleblower counsel. Questions about anonymity, signatures and identity belong in that conversation, where we can address your circumstances alongside the award application.

What Constitutes a Related Action?

A related action is an action by another qualifying authority based on the original information that led to successful CFTC enforcement. Federal, state and foreign authorities can be involved. The connection runs through the information and its use by each authority.

The same conduct can produce several proceedings. For an award claim, we examine which authority received the information, what it did with it and which judgment the claim concerns. A successful CFTC action below the ordinary covered-action threshold can also support a qualifying related-action claim.

The CFTC does not post notices for other authorities’ related actions. Their judgments and their order relative to the CFTC action matter to the application. Our review follows that chronology, including any SEC award involving the same action.

CFTC WB-APP Review, Objections and Record Requests

We handle CFTC WB-APP objection and record request deadlines with the whistleblower lawyers working on your claim. These concern the preliminary award decision, a separate stage from the Notice of Covered Action.

The Commodity Futures Trading Commission’s Claims Review Staff evaluates the claim. Its members were not directly involved in the underlying enforcement action. The staff’s Preliminary Determination states whether it recommends an award and the proposed percentage.

The award review process lets you see what the preliminary decision rests on and challenge it. For a claim based on investigative assistance, review can turn on whether that contribution has been understood and credited accurately. We bring the submission history and the account of that assistance into the review with you.

Can I Appeal an Award Decision?

Yes. We assess a final award decision and the review history with the whistleblower lawyers on your matter, including whether to pursue an appeal.

A Trading Explanation Changed the Award Decision

In an October 2021 award determination, the Commission awarded nearly $200 million to one whistleblower for a CFTC action and two related actions. The investigation was already open when the whistleblower contributed.

The whistleblower explained a trading position. That explanation helped investigators reach direct evidence and obtain admissions.

Staff had initially recommended denying the award. Additional information and a sworn statement from a federal regulator established the contribution on reconsideration. The resulting award covered the CFTC action, another federal action and a foreign action.

We see more than paperwork here. The insider’s explanation changed what investigators could prove. Showing the value of that explanation changed the award decision.

What Factors Does the CFTC Consider in Determining the Amount of the Award?

The Commodity Futures Trading Commission considers the significance of the information, the assistance provided, its enforcement interests and participation in internal compliance systems. Those factors connect the award review to the work the whistleblower actually contributed. Under the Commodity Exchange Act’s whistleblower provisions, qualifying whistleblowers collectively can receive 10% to 30% of monetary sanctions actually collected in an action.

The International Labour Office’s 2019 comparison of whistleblower laws describes another way whistleblowers share in recoveries: a False Claims Act case brought on the government’s behalf. A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers.

A CFTC whistleblower attorney reviewing an award application needs to understand both the market and the assistance given to investigators. We bring those parts together with you, from the meaning of a trading position to the evidence of how your explanation helped.

Your Contribution Belongs in the Award Claim

If you have helped explain the trading, transfers or reporting behind a CFTC action, speak with our whistleblower experts about pursuing the award claim. We assess how your information advanced the investigation and bring in CFTC whistleblower lawyers with the market and award experience your matter calls for. We stay alongside you through the application deadline and award review, pressing for your contribution to be understood and credited.