The Law of Insider Trading: Legal Theories, Common Defenses, and Best Practices for Ensuring Compliance

摘要: The government’s 2011 prosecution of hedge fund manager Raj Rajaratnam and the various investigations into use expert networks by funds other institutional investors have prompted questions about law insider trading, permissible methods gathering information, general defenses to allegations ways in which firms can reduce risks liability. As a first line defense, investment should ensure that robust comprehensive compliance programs are place risk potential trading. Regardless quality their procedures, however, financial services personnel may be suspected of, or even face criminal civil charges for To assist individuals considering weighing possible against actions brought Department Justice (“DOJ”) Securities Exchange Commission (“SEC”), this Article (1) provides an overview relevant regarding (2) discusses some legal factual raised, depending on facts circumstances case, (3) guidelines establishing maintaining effective program minimize trading Any firm becomes subject investigation mindful is nuanced highly dependent upon particular case. This analyzes current describes key raised consultation with counsel.