New Directions For SEC's Insider Trading Program

Law360, New York (April 29, 2013, 12:07 PM EDT) -- The U.S. Securities and Exchange Commission recently announced insider trading charges against a Canadian investment banker who allegedly traded on nonpublic information that he "pieced together" through interactions with a client.[1]

The case, SEC v. Moore, has garnered little attention to date. But it is significant because it highlights two active trends in the SEC's insider trading enforcement program: (1) the broadening of the definition of materiality and the corresponding erosion of the mosaic theory; and (2) the significant increase in cross-border insider trading actions. Both...
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