SEC v. Christopher Salis, et al. (insider trading, 2016)

Settled

✓ Checked against the primary document on October 4, 2026. The library's summary, tags and figures for this record were compared with the regulator's own document by an AI model (Claude) following written instructions, with sampled and disputed records read a second time. No lawyer has reviewed them. A checked record can still contain errors, and checked does not mean endorsed. See how we check records or report a correction.

Report an error in this record (sec-christopher-salis-et-al-insider-trading-2016) by email

In October 2016 the SEC alleged that an SAP executive and two friends traded ahead of SAP's acquisition of Concur. On June 12, 2019 the Northern District of Indiana entered consent judgments with injunctions and disgorgement totalling $358,520 plus $52,216 interest. All three had pleaded guilty in criminal cases.

The record

What was ordered

Civil penalty

—

Disgorgement

$359k

Prejudgment interest

$52.2k

Total relief

$411k

Alleged gain

—

A dash means the release did not state a figure we could extract, not that the figure is zero. Penalty and disgorgement are stored separately so aggregates across the library do not double-count the same dollars.

What is alleged to have happened

The SEC announced this action on October 21, 2016 as release LR-23674, naming Christopher Salis, Douglas Miller and Edward Miller. It alleged Salis tipped Douglas Miller about a pending corporate transaction, and Miller passed it on.

The technique tag is this library's own reading of the conduct the regulator describes; agencies charge statutory provisions, not technique names.

The SEC's June 2019 release (LR-24499) reports final judgments on consent entered June 12, 2019, with disgorgement of $90,400 plus $2,067 interest for Salis, $119,003 plus $22,258 for Douglas Miller and $149,117 plus $27,891 for Edward Miller, and permanent injunctions under Section 10(b) and Rule 10b-5 (plus Section 14(e) for Salis and Douglas Miller). The release reports guilty pleas and prison terms of 6, 24 and 6 months respectively; sentence months are not stored because they differ by defendant. No civil penalties are reported. Checked on 2026-10-04.

What technique is this, and how does it work?

This action is tagged with one technique in our taxonomy. The tagging is ours: regulators charge statutory provisions, not technique names, so the mapping is an editorial judgement described in our editorial policy.

• Insider trading — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2016-10-21 Litigation release published
2. 2019-06-12 Consent final judgments entered against all three defendants (SEC release LR-24499)

Primary documents

Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.

• SEC litigation release
• SEC litigation release on the final judgments (LR-24499)

The linked release is a work of the United States government and is not subject to copyright. Our summary and narrative above are our own writing.

Same matter

The library links these 3 records because they appear to concern one matter: the same lead defendant, an overlapping technique tag and close filing dates, or a shared court docket or a release that cites the other. Records are listed by date filed.

This grouping is the library's, made by matching names, techniques, dates and citations when the site is built. It is not the regulator's or a court's determination that the records are one case, and it errs towards missing a link rather than making a false one.

Related actions

Other actions in the library sharing at least one technique tag with this one.

Record added September 10, 2026. submit a correction.