News & Analysis as of

Securities Fraud Material Nonpublic Information Securities and Exchange Commission (SEC)

White & Case LLP

DOJ’s Novel Application of Insider Trading to 10b5-1 Plans Leads to Conviction

White & Case LLP on

In April, we issued an alert discussing the U.S. Securities and Exchange Commission ("SEC") and Department of Justice’s ("DOJ") expansion of insider trading to 10b5-1 plans. On June 21, 2024, a federal jury in California...more

BCLP

Conviction of Insider in Connection with 10B5-1 Trading Plan

BCLP on

As discussed in our March 3, 2023 post, the DOJ and SEC brought an insider trading case against the founder and former CEO and Executive Chairman of Ontrak, Inc. based upon the former executive failing the “clean hands”...more

BCLP

Post-Panuwat: Have You Reviewed and Updated Your Insider Trading and Other Corporate Policies?

BCLP on

As discussed in our September 1, 2021 post, the SEC brought its first “shadow insider trading” case against Matthew Panuwat, a company employee who purchased options in a competitor’s shares shortly after learning his...more

Holland & Knight LLP

Shady Days: SEC Secures Another Insider Trading Stat on Shadow Trading Theory

Holland & Knight LLP on

The U.S. District Court for the Northern District of California on May 30, 2024, approved a settled final judgment against technology company Arista Networks' former chairman and CEO, Andreas "Andy" Bechtolsheim based on...more

Kramer Levin Naftalis & Frankel LLP

SEC Secures Jury Verdict in Shadow Insider Trading Trial

On April 5, 2024, a federal jury in San Francisco returned a verdict in favor of the Securities and Exchange Commission (SEC) in Securities and Exchange Commission v. Panuwat. The jury found that a corporate executive had...more

Tannenbaum Helpern Syracuse & Hirschtritt LLP

The SEC Wins First Insider Trading Case Based on So-Called “Shadow Trading” Theory

On April 5, 2024, a federal jury in SEC v. Panuwat (N.D. Cal.) agreed with the SEC that a corporate official engaged in insider trading when he purchased securities of a company based on material nonpublic information...more

Freeman Law

Insider Trading Law | An Evolving Landscape

Freeman Law on

Throughout the history of the U.S. stock market, individuals have used insider access to information to gain an unfair advantage over other investors. The use of material non-public information (“MNPI”) in financial trading...more

Jones Day

Insider Trading Enforcement in 2022

Jones Day on

Each year, the Department of Justice ("DOJ"), the Securities and Exchange Commission ("SEC"), and in recent years, the Commodity Futures Trading Commission ("CFTC") dedicate substantial resources to investigating and...more

Goodwin

Jury Acquits Tesla and Musk of Securities Fraud for 2018 Tweets Regarding Going Private

Goodwin on

On February 3, 2023, in the matter In re Tesla Inc. Securities Litigation, Case No. 3:18-cv-04865, a California federal jury cleared Tesla, Inc. (Tesla), and CEO Elon Musk of claims that they committed securities fraud,...more

Morgan Lewis

Insider Trading: Can There Be a Tippee Without a Tipper?

Morgan Lewis on

It is generally understood that it is unlawful to trade on nonpublic, market-moving information, or tips from someone with inside information—but what if the tip was not unlawful in the first place? When someone receives a...more

BCLP

Criminal indictment of Executive Chairman and parallel civil charges show Feds' willingness to challenge Rule 10b5-1 trading plans

BCLP on

The Justice Department recently indicted the Executive Chairman of Ontrak, Inc. alleging that he failed the “clean hands” requirement because he had been aware of material nonpublic information relating to the potential loss...more

Katten Muchin Rosenman LLP

Record Penalty for Alleged Regulation FD Violations and Best Practices Going Forward - Capital Markets Compass | Issue 5

On December 5, 2022, a large telecommunications company (the Company) and the US Securities and Exchange Commission (SEC) agreed to settle long-standing charges that executives allegedly had selectively disclosed material...more

Eversheds Sutherland (US) LLP

SEC amends Rule 10b5-1 and revamps affirmative defense to insider trading charges

The Securities and Exchange Commission (SEC) has unanimously adopted amendments to Rule 10b5-1 (the Rule), which prohibits the purchase or sale of securities on the basis of material nonpublic information (MNPI) in violation...more

Goodwin

SEC Enforcement Against Cheetah Mobile Execs Reflects Heightened Scrutiny of 10b5-1 Plans

Goodwin on

​​​​​​​On September 21, 2022, the U.S. Securities and Exchange Commission (“SEC”) charged the CEO, Sheng Fu, and former president, Ming Xu, of Chinese-based technology company Cheetah Mobile Inc. (“Cheetah Mobile” or the...more

Kramer Levin Naftalis & Frankel LLP

SEC Rejects Rule 10b5-1 Defense in Enforcement Action Against Cheetah Mobile Executives

On Sept. 21, 2022, the Securities and Exchange Commission (SEC) announced that it brought an enforcement action against two executives of Cheetah Mobile, a publicly traded Chinese app developer, for selling the company’s...more

BakerHostetler

SEC Brings Flurry of Insider Trading Cases Using Market Analytics

BakerHostetler on

On July 25, 2022, the Securities and Exchange Commission (SEC or the Commission) made headlines announcing insider trading charges against 10 individuals across four separate cases, signaling an increased and renewed focus on...more

Akin Gump Strauss Hauer & Feld LLP

SEC Division of Examinations (Finally) Speaks on Alternative Data

Key Points - The SEC’s Division of Examinations published a risk alert that, in the context of a focus on MNPI, highlighted observed deficiencies related to the use of alternative data by private fund managers and other...more

Kramer Levin Naftalis & Frankel LLP

District Court Denies Motion to Dismiss SEC’s First ‘Shadow Trading’ Complaint

Judge William H. Orrick of the Northern District of California recently denied a motion to dismiss the Securities and Exchange Commission’s (SEC’s) first insider trading case charging a defendant with “shadow trading.” The...more

Proskauer - Corporate Defense and Disputes

SEC Defeats Motion to Dismiss Insider-Trading Complaint Alleging Novel “Shadow Trading” Theory

The SEC prevailed on a motion to dismiss a closely watched lawsuit alleging that the defendant had engaged in insider trading based on news about a not-yet-public corporate acquisition when he purchased securities of a...more

WilmerHale

SEC Insider Trading Enforcement Highlights from 2021

WilmerHale on

The Securities and Exchange Commission’s (SEC or Commission) actions in 2021 demonstrate that insider trading remains a key enforcement priority. While the absolute number of insider trading enforcement actions brought by the...more

Akin Gump Strauss Hauer & Feld LLP

A Quant and MNPI Enforcement Action - Important but Not for the Reasons You Might Think

On September 23, 2021, the U.S. Securities and Exchange Commission charged a quantitative analyst for “a scheme to violate the federal securities laws by using material nonpublic information to secretly trade ahead of (i.e.,...more

Akin Gump Strauss Hauer & Feld LLP

New Shadow Trading Enforcement Lessons For Private Funds

The U.S. Securities and Exchange Commission has a long history of adopting novel theories in litigation to convince the courts to expand the scope of the federal insider trading laws. The SEC's latest effort comes in an...more

Troutman Pepper

Securities & Exchange Commission Tests New Insider Trading Theory

Troutman Pepper on

The Securities & Exchange Commission (SEC) is experimenting with a new theory of liability that potentially expands the bounds of the insider trading laws. Specifically, the SEC is requesting that a California court deem the...more

Akin Gump Strauss Hauer & Feld LLP

New “Shadow Insider Trading” SEC Enforcement Action -- Four Lessons for Private Fund Managers

Last week, the U.S. Securities and Exchange Commission filed a complaint in federal court in California premised on the novel legal theory that the insider trading laws apply where an insider uses confidential information...more

Proskauer - The Capital Commitment

Three Key Considerations for Fund Sponsors when Participating in Bankruptcy Proceedings

We anticipate a more assertive regulatory enforcement program under the Biden administration, particularly focused on fund managers’ conflicts of interest, advisers’ codes of ethics, and related policies and procedures...more

42 Results
 / 
View per page
Page: of 2

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide