The fourth installment in a six-part series, Outten & Golden’s Whistleblower & Whistleblower Retaliation Practice examines the securities violations central to the SEC’s enforcement agenda.

In April 2026, David Woodcock took the reins as the Director of Enforcement for the Securities and Exchange Commission. In his first public remarks, Director Woodcock delivered a keynote address at the MFA Legal & Compliance 2026 Conference outlining a traditional enforcement agenda focused on high-impact cases in the following areas: Offering Fraud, Accounting and Disclosure Fraud, Market Manipulation, Insider Trading, Private Funds, and Cross Border Fraud.

Here we focus on insider trading — one of the SEC’s longest-standing enforcement priorities and an area that continues to evolve as markets, technology, and trading strategies become increasingly sophisticated.

Key Facts

• Insider trading threatens the level playing field that U.S. securities markets depend on. By using material, nonpublic information for personal gain, individuals can profit at the expense of investors who do not have access to the same information.
• Insider trading remains one of the SEC’s longest-standing enforcement priorities. While traditional cases involving corporate executives remain common, the SEC has expanded its focus to include digital assets, hedge funds, professional advisors, and emerging theories such as “shadow trading.”
• The SEC increasingly relies on sophisticated data analytics to uncover insider trading. Modern investigations often focus on trading patterns, communications, and networks of connected individuals rather than isolated trades by corporate insiders.

What is Insider Trading?

Insider trading occurs when an individual buys or sells securities while in possession of material, nonpublic information — information that has not been disclosed to the broader market and that a reasonable investor would consider important when making an investment decision.

The concern at the heart of insider trading enforcement is market fairness. Investors should compete on a level playing field, and those with access to confidential information through their position, relationships, or professional obligations cannot use that information for personal gain.

The basic components of an insider trading case include:

• Material Information – what a reasonable investor would consider important in making an investment decision – might include information on pending mergers, regulatory approvals, results of clinical trials, unanticipated earnings releases, or the award (or loss) of lucrative contracts.
• The information has not been released to the investing public through appropriate channels.
• The insider is an individual who receives confidential information through employment, professional services, or another relationship of trust and improperly uses that information to trade or provide tips to others.

The SEC typically brings anywhere from a handful to a few dozen insider trading cases each year. The authorities’ methods of enforcement have evolved alongside the sophistication of securities frauds. Today, the SEC targets big networks, using sophisticated data analysis, communications review, and trading-pattern analytics rather than traditional allegations of executives personally trading ahead of earnings announcements.

What are recent trends and themes in insider trading?

While traditional insider trading cases remain a core focus, the SEC’s approach has expanded as markets and trading practices have changed.

• Corporate insiders remain a primary focus. The SEC continues to pursue cases involving executives and employees who trade around significant corporate events, including earnings announcements, mergers and acquisitions, government approvals, and regulatory decisions.
• Digital assets have emerged as a key area of scrutiny. The Commission has pursued allegations involving confidential information related to token listings, exchange activity, and other developments in the crypto markets.
• Professional gatekeepers are under continued examination. Lawyers, accountants, investment bankers, and other advisors with access to confidential information through their work remain a focus when they allegedly misuse information obtained through transactions, litigation, financial reporting, or other engagements.
• Hedge funds and alternative investment firms remain enforcement priorities. The SEC continues to examine whether firms and their employees are improperly trading on information obtained through expert networks, analysts, industry contacts, or other sources.
• “Shadow trading” represents an emerging enforcement theory. In these cases, individuals use confidential information about one company to trade securities of another company that may be affected by the same information.
• Compliance and recordkeeping remain important. Failures to properly document trades, holdings, or required filings have resulted in numerous enforcement actions in recent years.

What are some of the SECs most significant insider trading cases?

• In 2026, the SEC charged 21 individuals for their alleged involvement in a massive decade-long insider trading scheme in which corporate attorneys passed on confidential deal information for the purposes of making millions in illegal profits.
• Billimek/Williams. Over a five-year period, Billimek, a trader with a major asset manager, tipped details of his firm’s major trades so that Williams could execute illegal trades based on the securities’ anticipated movement in the market. The scheme resulted in proceeds of over $47 million. The two individuals were ordered to pay over $38 million in restitution. Billimek was also ordered to pay $12.25 million in criminal forfeiture.
• CR Intrinsic/SAC Capital Advisors. CR Intrinsic was an affiliated hedge fund managed by SAC Capital Advisors, and both were embroiled in a $276 million insider trading scheme involving drug trials. CR Intrinsic agreed to pay roughly $600 million to settle the case. SAC Capital was initially named by the SEC in the CR Intrinsic case because funds managed by SAC Capital received portions of the ill-gotten gains. SAC Capital ultimately pleaded guilty to criminal insider trading charges in a separate, broader case brought by the Department of Justice, resulting in a staggering $1.8 billion criminal and civil settlement.
• Raj Rajaratnam/Galleon Group. The Galleon Group insider trading case was a massive financial scandal centered around billionaire hedge fund founder Raj Rajaratnam, who used a network of corporate insiders to illegally trade stocks. In addition to an 11-year prison sentence, together with the parallel criminal case, total monetary sanctions imposed on Rajaratnam exceeded $156 million.
• Rajat Gupta/Goldman Sachs. Former Goldman Sachs board member Rajat Gupta was fined $13.9 million for passing confidential information to hedge fund manager Raj Rajaratnam, who traded on the board member’s tips. Together with the criminal penalty, total monetary sanctions against Gupta approached $19 million.
• Jeffrey Skilling/Enron. Prior to the public learning of Enron’s dire situation, Skilling, Enron’s former CEO, sold off $60 million of company stock. In connection with his case, which included other securities violations, Skilling was ordered to pay $42 million in restitution.  

Although insider trading remains a significant SEC enforcement priority, it represents a relatively small percentage of whistleblower submissions received by the Commission.

Retaining Expert Legal Services

If you have information regarding potential offering fraud or other securities violations, the Whistleblower & Whistleblower Retaliation team at Outten & Golden provides dedicated guidance and legal representation to protect your rights and help you safely navigate the reporting process. Explore our resources to learn more about how we assist individuals in exposing corporate wrongdoing.