SEC Charges Partner at Global Consulting Firm With Insider Trading


The Securities and Exchange Commission today charged Puneet Dikshit, a partner at a global management consulting firm, with illegally trading in advance of a corporate acquisition by one of the firm’s clients in September.

The SEC’s complaint, filed in federal district court in Manhattan, alleges that in the course of providing consulting services, Dikshit learned highly confidential information concerning The Goldman Sachs Group Inc.’s impending acquisition of the consumer loan fintech platform GreenSky Inc. According to the SEC’s complaint, in the days leading up to the acquisition announcement on Sept. 15, 2021, Dikshit used this information to purchase out-of-the-money GreenSky call options that were set to expire just days after the announcement. The SEC’s complaint further alleges that Dikshit violated his firm’s policies by failing to pre-clear these options purchases, which he sold on the morning of the acquisition announcement for illicit profits totaling over $450,000.

“We allege that Dikshit breached duties to his employer and his client by misusing their confidential information for his own financial gain,” said Joseph G. Sansone, Chief of the SEC Enforcement Division’s Market Abuse Unit. “Thanks to our trading analysis tools, we were able to move swiftly to hold him accountable for his actions and protect the fairness of our securities markets.”

In a parallel action, the U.S. Attorney’s Office for the Southern District of New York today announced criminal charges against Dikshit.

The SEC’s complaint charges Dikshit with violating Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder and seeks a permanent injunction and a civil penalty.

The SEC’s investigation was conducted by Joshua I. Brodsky of the Complex Financial Instruments Unit and David Bennett and Patrick McCluskey of the Market Abuse Unit. The case was supervised by Osman Nawaz of the Complex Financial Instruments Unit, and Mr. Sansone. The SEC’s litigation will be led by Alexander Vasilescu of the New York Regional Office. The SEC appreciates the assistance of the U.S. Attorney’s Office for the Southern District of New York and the Federal Bureau of Investigation.

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