“Shadow Trading” Becomes Insider Trading
Reynolds Holding
MARCH 28, 2022
2] However the SEC does seek a monetary penalty in an unspecified amount, a bar from serving as an officer or director of a public company, and injunctive relief. The District Court’s Refusal to Dismiss. 4] The court thus knew it was writing on a clean slate as it weighed the SEC’s new “shadow trading” theory of insider trading.
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