In August 2011, the controversial Dodd-Frank whistleblower rules took effect, raising concerns that the number of employees reporting corporate wrongdoing to the government, already growing as a result of the incentives under the False Claims Act and other statutes, would mushroom out of control.

While the Sarbanes-Oxley Act (SOX) encouraged whistleblowers to come forward by creating both civil and criminal retaliation enforcement regimes to protect those who report corporate fraud, the Dodd-Frank Wall Street Reform and Consumer Protection Act added a powerful incentive, offering whistleblowers between 10 percent and 30 percent of any recovery of more than $1 million in penalties.