Jail, $8.5‑Million Forfeiture and Industry Bar for Securities Analyst in Front‑Running Scheme

In 2021, the SEC and DOJ charged a securities analyst with multiple counts of securities fraud in connection with a years-long front-running scheme in which he allegedly made approximately $8.5 million in illicit profits by trading ahead of his employer, a large investment adviser, in an undisclosed account in his wife’s name. Earlier this year, the analyst pleaded guilty to one count of securities fraud, forfeited his trading profits and was sentenced to jail for his crime. The parallel SEC enforcement proceeding ended with an industry bar for the analyst, injunctive relief and a disgorgement order. This article details the terms of the civil and criminal resolutions, with thoughts on the implications of the actions from Akin Gump partner Brian Daly. For more on personal trading, see our three-part series on code of ethics fundamentals: “Why Fund Managers Need Them” (May 20, 2021); “What They Must – and May – Include” (Jun. 3, 2021); and “How to Monitor and Enforce Compliance With Them” (Jun. 10, 2021).

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