We have extensive experience representing public companies, broker-dealers, hedge funds, alternative investment funds, and other entities, as well as individuals such as directors, officers, traders, analysts, and other employees, in connection with insider trading investigations conducted by the SEC, DOJ, and other regulators. We know how the relevant securities provisions work, and we understand the insider trading investigatory process.
Our experience with respect to insider trading and related issues includes matters involving:
- investigations into allegations of "traditional" insider trading against directors, officers, or employees of a public company;
- investigations into allegations of "tipper" or "tippee" liability;
- investigations into allegations of insider trading pursuant to the "misappropriation theory" of insider trading;
- investigations into allegations involving novel theories of derivative liability against persons who are otherwise unrelated to a public company;
- investigations into "hybrid" allegations involving more than one theory of insider trading;
- routine inquiries by FINRA, other self-regulatory organizations, and the SEC into trading patterns in connection with announcements by public companies or other events; and
- corporate and broker-dealer compliance work involving implementing or revising supervisory and compliance systems, internal controls, and policies and procedures relating to insider trading.