Salman reaffirms Dirks and holds that a “gift” of inside information to a trading relative or friend continues to meet the personal-benefit requirement.

The Salman Prosecution -

In 2011, Bassam Yacoub Salman was indicted on four counts of securities fraud and one count of conspiracy to commit securities fraud. At trial, the government produced evidence showing that Salman had received material, nonpublic information about healthcare deals from Mounir “Michael” Kara, who had in turn received that information from Michael’s brother and Salman’s brother-in-law, Maher Kara, an investment banker at the time. The government further showed that Salman used the inside information to net US $1.5 million in trading profits.