Q4 Insider Trading Enforcement Actions (12/23/25)

During Q4, final judgments were entered in District Courts in New York and Texas against individuals who were previously charged in insider trading cases brought by the SEC's Market Abuse Unit. Bryan Scott McMillan of Texas obtained information from a domestic partner who worked at Apollo that the firm would be acquired by another company. He was ordered to pay disgorgement with interest totalling $99,660 plus a civil penalty of $122,100 and is further subject to an officer and director bar. In addition, Anthony Viggiano of New York, a former financial industry analyst, learned about impending M&A transactions and strategic partnerships while working at two financial institutions and tipped two of his close friends about the upcoming deals, who subsequently traded in advance of the transactions, resulting in illegal gains. We expect insider trading investigations and enforcement actions to continue in the coming year, both against those who themselves misuse material nonpublic information for illegal trading as well as those who tip such information to others. See https://www.sec.gov/enforcement-litigation/litigation-releases/lr-26417 and https://www.sec.gov/enforcement-litigation/litigation-releases/lr-26454.