On 15 January 2016, the SEC announced a whistleblower award of more than $700,000 to an individual who did not work for the company in question, but, as an industry expert, produced a detailed analysis leading to a successful SEC enforcement action. This was the first ever whistleblower award to a company outsider since the beginning of the SEC whistleblower programme in 2011.

The SEC has commended whistleblowers who voluntarily provide unique and useful information that leads to successful enforcement action, and incentivises with awards between 10% and 30% of the money collected where the monetary sanctions exceed $1 million. This first outsider award may encourage further claims from potential outsider whistleblowers and may result in situations where the SEC is made aware of problems before the company itself.