CFTC Enforcement and Whistleblower Awards Plunged in 2025
After a strong 2024, the CFTC whistleblower program experienced a decline in both enforcement and award payouts in fiscal year 2025.1 Though the agency received 1,697 tips during this year (just 47 below last year’s record total) and 203 Form WB-APP submissions, enforcement recoveries and awards are down significantly.
The agency publicized that it only had 13 new enforcement actions in 2025: seven new administrative cases and six civil injunctive cases. But in 2024, the agency filed over four times as many new enforcement actions. We estimate that the agency only recovered approximately $859 million in monetary relief for enforcement actions in 2025,2 quite short of the 2024 record-total of $17.1 billion in monetary relief.
The CFTC also granted just three whistleblower awards in 2025, totaling $4.6 million; the associated enforcement actions for these awards collected over $16 million in sanctions. During this same period, the CFTC denied award claims for 120 claimants. Compared to last year’s payouts, this year’s awards are approximately 11% of last year’s impressive $42 million in awards.
Billions of fraud dollars related to CFTC priorities still flow through the economy and go uninvestigated. The CFTC Chairman, Michael S. Selig, affirmed that the agency’s 2025 enforcement priorities returned to the bread-and-butter market fraud the CFTC has always had under its purview. Specifically, the CFTC is focused on: insider trading, market manipulation, market abuse, retail fraud (including Ponzi schemes), and willful failures to follow anti-money laundering and know-your-customer laws.
During this same year, the FBI estimated that Americans were defrauded of nearly $21 billion from cyber-schemes including cryptocurrency, phishing/spoofing, extortion, and investment schemes. And though by its own statements, the CFTC has moved away from cryptocurrency-related enforcement, perhaps the agency should reconsider. Indeed, the CFTC has enforced in cryptocurrency and money-laundering cases before and it is estimated that in 2025, $82 billion in illicit cryptocurrency funds were laundered.
With this many fraudulent dollars flowing freely, where are the enforcement results? Based on the number of tips, it is hard to believe that it is a lack of information from insiders that is the problem. And the CFTC’s Division of Enforcement’s budget was $5.5 million higher than last year’s for a total of $74 million.
The agency also announced its intent to prioritize enforcements related to prediction markets in the coming year. Trading volume in the prediction markets for 2025 exceeded $40 billion and is only likely to increase, representing another potential source of enforcement boons for the CFTC.
The CFTC whistleblower program has a lot going for it in terms of potential areas for enforcement that face significant annual fraud. We look forward to seeing how the agency steps up in the coming year to increase its enforcement efforts and reward deserving whistleblowers.
This piece was written by Erica Roberts, an Associate at Sanford Heisler Sharp McKnight
1 All years referenced are the fiscal year, which for 2025 runs from October 1, 2024 to September 30, 2025.
2 This number is estimated from the CFTC press releases for fiscal year 2025 reporting enforcement recoveries. https://www.cftc.gov/LawRegulation/EnforcementActions/index.htm?year=2025&page=0
