The SEC, under the leadership of Chair Paul Atkins, has made good on its pledge to return to the agency’s core mission of market integrity. In recent weeks, the Commission—sometimes in coordination with the DOJ and FBI—has announced a series of insider trading cases that read like a throwback to classic enforcement playbooks.
For companies, boards, and compliance officers, these actions are not just routine headlines—they are a strategic signal. Insider trading remains a top enforcement priority, and regulators are expanding their focus beyond corporate insiders to include service providers and consultants with privileged market access.
Case Snapshots: A Return to Basics
Investor Relations Consultant Misuses Client Information: A former healthcare-focused investor relations executive, Robert Yedid, repeatedly tipped friends with confidential client information about drug trials, earnings, and M&A deals. His associates traded on at least five issuers, generating hundreds of thousands in illicit profits, with cash kickbacks funneled back to Yedid.
SEC v Yedid
Corporate Executive Breaches Confidentiality During M&A: At Kaman Corporation, Vice President Brent Cranmer tipped a friend about the company’s confidential sale process (“Project Safeguard”). His contact in turn tipped his friend and asked him to trade on behalf of Cranmer. The contacts traded stock and options for themselves, reaping over $1 million. Cranmer himself did not trade and the contacts did not trade on his behalf, but the SEC still treated his conduct as unlawful tipping for personal benefit.
SEC v Cranmer
Filing Agent Employees Exploit Early Access to SEC Filings: Justin Chen and Jun Zhen, employees of a leading EDGAR filing agent, traded ahead of multiple Form 8-K announcements (Ondas Holdings, Purple Innovation, SigmaTron, Signing Day Sports). They netted over $2.2 million combined. Here, the FBI led the investigation and the DOJ brought parallel criminal charges, demonstrating multi-agency alignment and the criminal seriousness of such misconduct.
USA v. Justin Chen and Jun Zhen
SEC v. Justin Chen and Jun Zhen
Board Member’s Family-and-Friends Tipping Ring: In August 2025, the SEC charged former Chinook Therapeutics board member Ross Haghighat for tipping his brother, stepdaughter, and close friends with material nonpublic information (MNPI) about Chinook’s pending $3.2 billion acquisition by Novartis. Haghighat’s circle of tippees executed highly opportunistic trades in Chinook common stock and short-dated call options, collectively generating over $500,000 in illicit gains. The SEC also alleged Haghighat himself traded through a custodial account for a minor stepchild. Notably, text messages and bank transfers revealed explicit coordination, including post-trade fund transfers back to Haghighat, undercutting any defense of inadvertence or lack of benefit. The SEC seeks disgorgement, civil penalties, and a director-and-officer bar against Haghighat, a severe sanction signaling heightened scrutiny of governance breaches at the board level, and the Department of Justice pursued a parallel criminal investigation against the defendants.
Strategic Enforcement Themes
1. Insider Trading Is Back in Focus: These are classic “tipper–tippee” misappropriation cases—insiders or advisors exploiting MNPI for profit. Haghighat exemplifies the Commission’s resolve to pursue cases involving directorial misconduct at the highest levels, demonstrating (again) that even seasoned board members are not insulated from aggressive enforcement.
2. Multi-Agency Coordination Is Rising: The Chen/Zhen matter illustrates collaboration with FBI and DOJ. In Haghighat, the SEC relied heavily on detailed digital communications and financial records, methods that could also support parallel criminal proceedings. Companies should anticipate both civil and criminal exposure when insider trading touches M&A activity.
3. Third-Party Risk Cannot Be Ignored: Yedid (IR consultant) and Chen/Zhen (filing agents) show the vendor risk profile. Haghighat takes this further: the familial and personal network of a board member became the vector for misconduct. Compliance programs cannot assume family members, household accounts, or close friends are beyond enforcement risk.
4. Accountability Goes Beyond the C-Suite: Cranmer (VP), Chen/Zhen (mid-level employees), and Haghighat (director) underscore the breadth of accountability. Haghighat’s case is particularly instructive: it shows that a board seat carries enhanced fiduciary exposure—a breach at that level risks not just individual liability but reputational damage for the issuer and its governance structures.
5. A Global Parallel: Chinook’s acquirer, Novartis, is a Swiss-based multinational, highlighting the cross-border nature of insider trading enforcement. With the SEC coordinating alongside global regulators (e.g., ESMA, FCA), boards of multinational firms must recognize that one jurisdiction’s leak can cascade into multi-jurisdictional enforcement.
Action-Oriented Guidance for Boards and Executives
- Strengthen MNPI Controls: Directors should be explicitly re-trained on insider trading policies and reminded of fiduciary duties. Haghighat was directly aware of Chinook’s insider trading policy yet chose to breach it. Companies must randomize audits of board members’ trading-related communications and consider forensic monitoring of digital activity tied to board-level access.
- Elevate Training Programs: Annual compliance refreshers are insufficient. Real-world case studies—Haghighat (board misconduct), Yedid (consultant tipping), Cranmer (mid-level executive breach)—should form the backbone of scenario-based board and executive training.
- Enhance Trading Surveillance: Forensic surveillance should track not only employee accounts but also related-party accounts (trusts, household members, affiliated entities). Haghighat’s use of a custodial account and family members underscores the need for beneficial ownership mapping.
- Institute Vendor and Director Oversight Protocols: Beyond vendor contracts, issuers should formalize director-level attestations of compliance with MNPI policies and require prompt disclosure of related-party accounts. Enforcement is trending toward imposing oversight obligations squarely on the board.
- Prepare for Multi-Agency and Cross-Border Scrutiny: The Haghighat matter demonstrates how personal communications, family financial transfers, and digital footprints form the evidentiary backbone. Issuers must ensure that internal investigations are structured with an eye toward both SEC and DOJ standards, as well as potential foreign regulator inquiries.
- Run “Red Team” Governance Drills: Simulate breaches at the board level to stress-test whether compliance, audit, and legal functions could detect and respond before regulators intervene. Haghighat’s misconduct illustrates the risk of board-level blind spots.
Conclusion: A Moment for Proactive Leadership
Chair Atkins has signaled that the SEC will focus on enforcement actions central to its mission. These recent cases—Haghighat, Yedid, Cranmer, Chen/Zhen—are part of a broader reset to core priorities. The lesson from Haghighat is especially clear: one director’s breach of duty can unleash civil liability, criminal referral, and reputational harm that cascades across the enterprise. Now is the time to reassess vendor oversight, refresh compliance playbooks, and test internal safeguards. Leaders should be asking today: How would our governance and compliance structures withstand SEC scrutiny if a board member misused MNPI tomorrow?
1 This memorandum is provided by Bradford Edwards LLP for educational and informational purposes only and is not intended and should not be construed as legal advice. This memorandum is considered to be advertising under applicable state laws.
