Until the 21st Century and the European Union's market abuse laws, the United States was the leading country in prohibiting insider trading made on the basis of material non-public information.[5] Thomas Newkirk and Melissa Robertson of the U.S. Securities and Exchange Commission (SEC) summarize the development of US insider trading laws.[2] Insider trading has a base offense level of 8, which puts it in Zone A under the U.S. Sentencing Guidelines. This means that first-time offenders are eligible to receive probation rather than incarceration.[16]