Jordan A. Thomas discusses first-ever SEC whistleblower award issued to a corporate officer

Few details exist publicly about the officer or the enforcement action because the Securities and Exchange Commission (SEC) maintains very strict anonymity protections for its whistleblowers. But it is known that he or she tried reporting the problem internally before taking it outside the organization.

"The person reported, and the company failed to respond. In doing so, they invited much bigger problems to their organization. Before Dodd-Frank, companies could have some comfort in the fact that few people are likely to know about the wrongdoing, but here, where you have virtually all employees within an organization deputized to report wrongdoing, it's incredibly risky for companies to take that risk, and this is evidence of it," according to Labaton Sucharow LLP's Jordan Thomas, who represented the officer in question.

SEC whistleblower chief Sean McKessy declined to comment on the reporting requirements beyond what is written in the SEC's rule.

"The SEC whistleblower program is not explicit in what the reporting looks like, because every organization is different and because every person is in different places within the organization," Thomas said.