Recent SEC enforcement actions charging senior lawyers at Apple and SeaWorld with insider trading provide reason to dust off company insider trading policies and assess whether updates or additional training are needed. As sanctuaries for corporate America’s most valuable confidential information, law departments are among the first places that regulators look when trying to determine the source of a trader’s material nonpublic information.
Insider trading enforcement remains a cornerstone of the SEC’s enforcement program. Over the past ten years, the SEC has significantly enhanced its insider trading surveillance, detection and investigative capabilities. Through the adoption of new investigative approaches and … Read more