Esempi di insider trading: 12 casi che i dipendenti dovrebbero conoscere

Ultimo aggiornamento effettuato il 4 novembre 2026 confrontando i dati con le fonti citate in questo post.

In August 2025 the US Securities and Exchange Commission (SEC) charged two former employees of a company that helps clients make public filings. The SEC alleges they saw clients' forthcoming announcements, such as mergers and earnings results, before the market did. It alleges they then traded on at least 13 occasions between January and June 2025, made over $2 million, and did so despite their employer's ban on insider trading. They were not executives. They worked where the information passed through, and that is the pattern in most of the cases below.

This is a list of 12 insider trading examples in 3 sets, so you can pick and mix for a training session. Each case says what the person knew and what the SEC says happened. Each set ends with an La nostra scelta, the case we would discuss first, with one line on why.

These are examples drawn from SEC releases, not findings about your own situation. We describe only what each release says, and we use "alleged", "charged" or "settled without admitting or denying" exactly as the release does.

What counts as insider trading

Rule 10b5-1(a) treats buying or selling a security on the basis of material non-public information, in breach of a duty of trust or confidence, as a deceptive device under section 10(b) and Rule 10b-5. Under 10b5-1(b), a trade is "on the basis of" that information if the person was aware of it when they made the trade. Section 10(b) of the Securities Exchange Act bars manipulative or deceptive devices in contravention of SEC rules, and Regola 10b-5 makes it unlawful to use a device, scheme or act that operates as a fraud or deceit in connection with buying or selling a security.

Passing the information on is part of the picture. In the Kennedy and Roda cases below, the SEC charged both the person who shared the information and the friend who traded.

Two more rules sit behind these cases. Rule 10b5-1 also sets out defences for trades made under a plan adopted before the person became aware of the information. Rule 14e-3 covers tender offers: it makes it a fraudulent act for a person who holds material information about a tender offer, acquired from the bidder or the target, to trade on it unless the information has been publicly disclosed.

The rules reach outsiders too. In 1997 the Supreme Court in United States v. O'Hagan upheld the "misappropriation" theory under Rule 10b-5, in the case of a lawyer convicted for trading on confidential information that his firm's client planned a tender offer.

Set 1: employees who traded on what they saw at work

1. Chen and Zhen, filing-agent employees (LR-26380, 2025). They allegedly obtained advance knowledge of their employer's clients' coming announcements. The SEC asserisce at least 13 trades, over $2 million in profits, and a breach of the employer's insider trading prohibition. It was spotted by the SEC's Market Abuse Unit, which used Consolidated Audit Trail data to analyse their trading. They were also charged in a parallel criminal action.
2. Brett Kennedy, former Amazon financial analyst (2017-160). La SEC asserisce he accessed Amazon's non-public first-quarter 2015 earnings without authorisation and shared it with a former fraternity brother, who traded and made more than $116,000. The friend allegedly paid Kennedy $10,000 in cash. Kennedy agreed to a settlement, subject to court approval, of $10,000 disgorgement plus $875.36 interest. The US Attorney's Office announced parallel criminal charges the same day.
3. David Roda, software engineer at Penn Interactive (2022-105). He was given confidential information about Penn National's interest in acquiring Score Media, along with warnings not to trade on it. The SEC alleges he bought 500 call options and tipped a friend, Andrew Larkin, who bought 375 shares. When the deal was announced, Score Media's stock rose nearly 80 percent, and the SEC alleges their profits were $560,762 (Roda) and $5,602 (Larkin). Both agreed to settle, subject to court approval, and Larkin did so without admitting or denying.
4. Robert Gadimian, senior director at Puma Biotechnology (2016-205). La SEC asserisce he learned of positive developments in two clinical trials of his employer's drug and made over $1.1 million buying Puma stock and call options before each announcement (December 2013 and July 2014), and that he altered his trading records before giving them to Puma's internal investigation. He was fired in October 2014.
5. Yue Han, associate in Goldman Sachs' compliance department (2015-267). His job was building software to monitor colleagues for misconduct, which gave him access to investment bankers' deal emails. The SEC asserisce he used them to trade in at least four companies on the brink of being acquired, in his own account and his father's, for more than $450,000 in profits. The SEC obtained an emergency order freezing the assets.

Our pick: case 5, Yue Han. A compliance role gave him access to the very information he was meant to protect, which makes it the clearest example of a duty of trust.

Set 2: advisers, outsiders and the people they told

6. Dimitry Braverman, IT professional at Wilson Sonsini (2014-197). He had access to non-public information in the law firm's client databases. The SEC asserisce he made more than $300,000 trading ahead of merger announcements. When a lawyer at his firm was charged in a separate case, it says he sold, waited about 18 months and resumed in an account in the name of a relative who lives in Russia. SEC investigators traced the pattern back to him.
7. Raben and Borchard, PwC (2008-6). Borchard worked on due diligence for clients considering acquisitions. The SEC asserisce he told his friend and co-worker Raben about confidential plans on six occasions in 2006, and Raben bought stock ahead of the news, netting more than $20,000. PwC's Office of General Counsel uncovered it and referred it to the SEC. Both settled without admitting or denying. Borchard, a licensed CPA, was denied the privilege of appearing before the Commission as an accountant, with the right to apply to resume after three years.
8. Vinayak Gowrish, associate at TPG Capital (2009-266). La SEC asserisce he misappropriated and tipped information that TPG was negotiating to acquire Sabre Holdings, TXU and Alliance Data Systems. The tip allegedly passed through Zaman to two traders, Vaghar and Khoury, and Gowrish received cash kickbacks from Vaghar.
9. Adnan Zaman, vice president at Lazard (2009-266). la stessa pubblicazione asserisce he tipped information about two Lazard clients' acquisition negotiations to the same two friends. Across the whole scheme the two friends made nearly $500,000. In return he received cash, free rent and other items worth approximately $70,000. The group allegedly used coded text messages and sticky notes. Zaman offered to settle and agreed to be permanently barred from associating with any broker or dealer.

Our pick: case 9, Zaman. The reward came back in cash, rent and purchases, which is a reminder that a payment does not have to be money to be part of the story.

Set 3: landmark and high-profile cases

10. Woojae "Steve" Jung, vice president of investment banking (2018-97). La SEC asserisce that between 2015 and 2017 he traded in 12 companies ahead of announcements, through a friend's account in South Korea, for about $140,000. The account allegedly let him skirt his employer's rules to pre-clear trades and use an approved broker. SEC data analysis spotted the pattern and traced it back to him.
11. Matthew Panuwat, head of business development at Medivation (2021-155). He learned that Pfizer would acquire Medivation. The SEC presunta he bought short-term call options in Incyte, a comparable company, within minutes of learning it, despite a Medivation policy forbidding trading in other companies' securities on that information. The SEC alleged a profit of $107,066. After an eight-day trial, a jury found him liable on 5 April 2024.
12. Martha Stewart and Peter Bacanovic (2003-69, 2006-134). La SEC presunta that Stewart sold all 3,928 of her ImClone shares on 27 December 2001 after a tip from her broker, Bacanovic, that the company's CEO and his daughter were selling. The next day ImClone said the FDA had refused to file its drug application, and the shares fell 16 percent. In 2006 both settled without admitting or denying. Stewart paid $58,062 in disgorgement and interest and a $137,019 penalty, and accepted a five-year bar from serving as a director of a public company. Bacanovic paid a $75,000 penalty and $645 in disgorgement and interest.

Our pick: case 11, Panuwat. It shows the allegation can reach a comparable company's shares: he traded in a different company from his own.

Five habits that keep you out of trouble

These are workplace habits, not statements of what the law allows.

1. Check the restricted list before you trade. If your employer keeps one, use it every time. In the Jung case the SEC alleges he skirted his employer's pre-clearance and approved-broker rules by using a friend's account.
2. Never trade on a deal you worked on. Chen and Zhen allegedly made over $2 million on at least 13 occasions, using clients' forthcoming announcements they learned of through their jobs.
3. Do not pass a tip on, even to family or a friend. In the Kennedy, Roda and Raben cases, the person who shared the information was charged too.
4. Ask compliance before you act. If you are unsure whether something counts as inside information, ask first and do not trade or tell anyone meanwhile.
5. Assume a trade will be reviewed. The SEC used data analysis in the Chen and Zhen, Han, Jung and Braverman cases to find trading patterns and trace them back to the person.

A 12-question refresher quiz

A good refresher uses one question per case: "Did the person trade, tip, or both?" Here are two samples, with the answers as the releases give them.

• Kennedy: Did the former Amazon analyst trade, tip, or both? Tipo. The SEC alleges he shared earnings information with a friend, who traded.
• Ruota: Did the Penn Interactive engineer trade, tip, or both? Entrambi. The SEC alleges he bought call options himself and tipped a friend, who bought shares.

Add a second question to each case: "What should the person have done instead?" That is where the discussion happens.

Ways to host this refresher with a group

You can run the cases live in a classroom, an all-hands or a video call, and the answers appear on screen as people respond.

1. Pick Answer: the 12-case quiz. One question per case, with the answer revealed after the group votes.
2. Word Cloud: "What would you do if a friend asked about your deal?" The biggest words show how the group would react.
3. Rating Scale: "How confident are you spotting inside information?" Ask before and after the session and compare the averages.
4. Open Ended: "Which case surprised you?" Collect answers anonymously, so quieter people join in.

If you want a ready-made session, the Insider trading & confidential information course template gives you slides to adapt. For related reading, see our guide to AML red flags for frontline staff, La trappola della conformità and why employees pass training but struggle on the job.

Domande frequenti

What counts as insider trading?

Trading in a security while aware of material non-public information, in breach of a duty of trust or confidence, or tipping someone who does, as the SEC's cases show. Regola 10b5-1 and Regola 10b-5, made under section 10(b) of the Securities Exchange Act, set out the basis.

Is it illegal to trade on a tip from a friend?

It can be. The SEC has charged both the person who passed on a tip and the person who traded, for example in the Kennedy and Roda cases above.

Can an ordinary employee commit insider trading?

Yes. The Chen and Zhen case involves employees of a filing agent, and Roda was a software engineer. Neither was an executive.

What is a 10b5-1 plan?

A pre-arranged trading plan, set up before the person is aware of inside information. Rule 10b5-1(c) sets out when such a plan works as a defence, so read the rule and ask your compliance team rather than relying on a summary.

What should I do if I think I have inside information?

Do not trade and do not tell anyone, and ask your compliance team first. This is general guidance, not legal advice.

Dove iniziare

Pick one set and use it in your next compliance session. If you can only discuss one case this month, start with case 1, because it is the most recent and shows the whole pattern in one line.

Questo post fornisce informazioni di carattere generale e non costituisce consulenza legale. Per decisioni relative al vostro specifico ambiente di lavoro, rivolgetevi a un avvocato specializzato in diritto del lavoro o all'autorità di regolamentazione competente.