SEC's $18.5M insider case shows where a shrunken enforcement docket still bites

The detection chain in this complaint deserves more attention than the dollar figure. By the SEC's account, the trading was not surfaced by the agency at all: after South Jersey Industries announced its take-private on February 24, 2022, a financial regulator prompted Bank of America to open an internal inquiry into trading in the stock ^[9]. The bank fired Satsky in March 2025 ^[10], roughly 37 months after the announcement ^[6]. The lawsuit came later still, docketed as 1:26-cv-07132 in the Southern District of New York ^[6].

That sequence matters for a program filing far fewer cases than it used to. Crypto penalties came to $142 million in 2025, under 3% of the prior year's total ^[15], which puts 2024 above roughly $4.7 billion ^[5]. The alleged profit in this single tipping case is about 13% of the entire 2025 crypto penalty take ^[4]. A claim under Section 10(b) and Rule 10b-5 ^[17] requires no new legal theory, and in this instance it required no original surveillance work either.

The arithmetic is worth doing yourself. Wolfe bought about 2.2 million shares for at least $53 million across November and December 2021 ^[4], an average near $24.09 a share ^[1]. Infrastructure Investments Fund agreed to pay $36 a share in a deal valued at $8.1 billion ^[7]. At that price the stake is worth about $79.2 million, some $26.2 million above the stated minimum cost, while the SEC alleges $18.5 million ^[2], because it measures the announcement-day jump rather than the spread to closing ^[5]. Against the stated outlay that is a return of roughly 35% ^[3], and the outlay is a floor, not a total.

The structure around the trades is unusually visible for a case at this stage. Eight entities are named as relief defendants, among them Evergreen Capital, Evergreen Financial, Empire Property Management and GAW Holdings, with Evergreen managing Wolfe family assets ^[19]. Satsky, 59, ran an energy and utility banking unit at a New York bank and was lead banker on South Jersey ^[2]; he and Wolfe were colleagues at Credit Suisse before both moved to Bank of America in 2012 ^[8]. The SEC says the two discussed a possible acquisition on several occasions, including at a nationally televised college basketball game they attended with their wives ^[20]. That is the kind of detail a bank compliance file and a subpoenaed calendar produce, not the kind a thinly staffed market-abuse screen produces on its own.