On April 5, 2024, a jury found Matthew Panuwat liable for insider trading under the SEC’s novel “shadow trading” theory. When Panuwat learned that his company was about to be acquired, he placed trades in a peer company in the same industry whose stock price was likely to be affected when the acquisition was announced. There is considerable concern that the SEC may apply this theory to trading by fund and asset managers, which often have multiple trading desks that may inadvertently and innocently trade in the securities of one company while a correlated company is on the manager’s restricted list. A program presented by the Alternative Investment Management Association (AIMA) took a deep dive into Panuwat and the case’s implications for private fund managers, as well as steps managers can take to mitigate the risks associated with shadow trading. The program, which was moderated by senior AIMA advisor Suzan Rose, featured Scott Black, chief legal officer and CCO at Hudson Bay Capital Management LP and former senior trial counsel and Assistant Regional Director in the SEC Division of Enforcement; and Robert S. Frenchman, partner at Dynamis LLP. This article distills their insights. See “SEC’s Novel ‘Shadow Trading’ Enforcement Action Gains Traction After Denial of Defendant’s Motion to Dismiss” (Mar. 3, 2022).