In contrast, in what are called “suspicious trading cases” the SEC typically moves quickly, even without facts or proof of key elements of the offense often citing a bevy of trading data and suggestive facts to secure a freeze order over what is believed to be illicit trading profits – the facts and proof of key elements can be developed later in discovery. This is precisely the approach used by the SEC in its latest suspicious trading case. SEC v. Yin, Civil Action No. 17 CV 972 (S.D.N.Y. Filed Feb 10, 2017).
via SEC Wins Freeze of $29 Million in Alleged Insider Trading Profits — SEC Actions
