Back in May 2012, Sean McKessy, chief of the SEC's Whistleblower Office, said he hoped the first whistleblower payout would be substantial and help motivate people who may be considering bringing a tip to the government. When the first payout finally came last month, it was for the not-so-staggering amount of $50,000.

McKessy would probably have been much more eager to announce an award more like what the Internal Revenue Service just confirmed it recently paid -- a massive $104 million award to a tax whistleblower named Bradley Birkenfeld. The WSJ reports that Birkenfeld received the award for providing the IRS with information about UBS's AG's "illegal encouragement of secret offshore accounts by U.S. taxpayers." UBS reportedly paid $780 million in 2009 to settle a criminal case concerning the matter.

The $104 million award is believed to be the largest reward ever given to a U.S. whistleblower, and is based on a statute that awards whistleblowers up to 30 percent of the revenue recovered by the IRS. Under Dodd-Frank, the SEC is similarly authorized to provide monetary awards in a range between 10 percent and 30 percent of the money collected using a whistleblower's information. 

As BuckleySandler's Thomas Sporkin, former Chief of the SEC's Office of Market Intelligence, told Corporate Crime Reporter this week, similarly large awards are possible under Dodd-Frank. Sporkin noted the AXA Rosenberg case, in which the SEC secured a $200 million settlement based on information from a senior executive at the firm. The case preceded the Dodd-Frank whistleblower program, but Sporkin said that "had this person come in through the whistleblower program, and the SEC had received a $200 million judgment, the executive likely could have claimed a $60 million bounty...."