The SEC announced the award of more than $22 million to a whistleblower whose detailed tip and extensive assistance helped the agency halt a well-hidden fraud at the company where the whistleblower worked.

The $22 million-plus award is the second-largest total the SEC has awarded a whistleblower. The largest, $30 million, was awarded in 2014.

There apparently is more to the story however. Footnote 1 to the related order states “Several other factors mitigating the Claimant’s culpability were also considered” but all the detail has been redacted.  So it appears the award recipient somehow engaged in culpable conduct, which the SEC took into account when determining the award.  One factor the SEC considered was that the recipient “did not financially benefit from the misconduct.”