PLI Briefing: In the “Shadow” of Panuwat: SEC Insider Trading Unit Alumni Discuss Compliance Considerations Following Successful Shadow Trading Enforcement Action
June 11, 2024
O’Melveny counsel Bill Martin will join a panel discussion on insider trading in relation to an expected increase in the SEC’s enforcement for “shadow trading,” following its “unmitigated victory in the Panuwat case” which found the defendant liable. Shadow trading is where a company’s confidential information is utilized to trade in the securities of another company to which it is economically connected. PLI advises that “in light of the heightened enforcement risk (and the overall aggressive enforcement climate), market participants should reassess and strengthen their compliance and supervisory regimes to address the risk of violations.”
The panel will address the following questions:
- What constitutes impermissible shadow trading?
- How is the SEC (and DOJ) likely to react to the government’s big victory in the first shadow trading enforcement action?
- What policies, procedures, and controls should regulated entities (e.g., broker-dealers, registered investment advisers) consider adopting to reasonably supervise and prevent shadow trading?
- What should a public company’s shadow trading compliance program look like? How else might the SEC look to expand its insider trading enforcement efforts?
In the “Shadow” of Panuwat: SEC Insider Trading Unit Alumni Discuss Compliance Considerations Following Successful Shadow Trading Enforcement Action
Tuesday, June 11, 2024
1: 00 pm – 2:00 pm ET
Learn more and register here.