A big part of the SEC and DOJ’s enforcement of the insider trading laws is to bring cases that will deter others from violating the insider trading laws in the future. Although the recently-concluded case against Thomas P. Flanagan ended with a lighter prison sentence than it could have, the full slate of consequences for Flanagan should be sufficient to make the next audit partner who is considering trading on a client’s non-public information think twice.
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‘Enforcement 40’ for 2020
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