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Mention the words “insider trading,” i.e., the improper buying or selling of securities while in possession of material nonpublic information (MNPI), and the mind might begin to conjure nail-biting clandestine information gathering schemes on the TV show Billions or the more mundane image of a hedge fund boss working the phones and slowly schmoozing and pressuring MNPI out of executives at publicly traded companies. These images are not surprising given that the SEC’s insider trading crackdown over the last decade, in the wake of SEC v. Galleon Management, LP, has mainly focused on illicit trading by corporate outsiders like securities traders, high-profile hedge funds, and financial industry professionals like lawyers and investment bankers.

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