“SOFT” PUBLIC DISCLOSURE AND PRIOR TRADING PLAN NOT ENOUGH TO AVOID SEC INSIDER TRADING SANCTIONS
On September 21, 2022, the SEC issued a cease-and-desist order and fines against the CEO and CTO of a mobile internet company (“ Company”) who earned approximately one third of its revenues by placing third party advertisements in its applications. They sold Company shares pursuant to a prior trading plan and before they filed the Company’s financial statements with the SEC. They avoided losses of $203,290 and $100,127 respectively. They were found to be in violation of the Exchange Act. Among various undertakings, they paid fines of $556,580 and $200,254 respectively.
A copy of the SEC order is found here.
A summary is found here.