The SEC has been focused on opportunistic stock trading by corporate insiders who have knowledge of enterprise data breaches. In this guest article, Greenberg Traurig counsel Darren Abernethy addresses the interplay between corporate insider trading and cybersecurity incidents, and suggests potential enforcement defenses. He also provides best practices and recommendations for preventing rogue employees and third parties from seeking to benefit in securities markets based on their insider awareness of security incidents. See “SEC Risk Alert Highlights Policy Design and Implementation Failures and Roadmaps Future Enforcement
” (Apr. 24, 2019).