SEC v. Zhichen Zhou and Yannan Liu (insider trading, 2015)

Settled

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The SEC's November 2015 insider trading case against Zhichen Zhou and his cousin Yannan Liu over MedAssets and Chindex trading ended in consent final judgments filed on 28 December 2015 in the Southern District of New York. Each is liable for $306,929.59 in disgorgement, jointly with the other, and each owes a $306,929.59 penalty. Neither admitted or denied the allegations.

The record

What was ordered

Civil penalty

$614k

Disgorgement

$307k

Prejudgment interest

—

Total relief

$921k

Alleged gain

$300k

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 Securities and Exchange Commission announced this matter on November 10, 2015 as release LR-23403. The respondents named are Zhichen Zhou and Yannan Liu (2 individuals, 0 entities). The action was brought in the U.S. District Court, Southern District of New York.

This library tags the matter as insider trading, based on the conduct the regulator describes. Each tag links to a page explaining how that technique works, what statute it engages, and what penalties comparable actions have attracted. The tagging is ours, not the regulator's: agencies charge statutory provisions, not technique names.

The conduct is recorded against equities.

The court entered a final judgment as to Zhou on 28 December 2015, and a matching judgment as to Liu, each consented to without admitting or denying the allegations. Each judgment enjoins the defendant from violating Section 10(b) and Rule 10b-5, makes him liable for disgorgement of $306,929.59 jointly and severally with the other, and imposes his own civil penalty of $306,929.59, so each owes $613,859.18 in total. The stored figures count the disgorgement once and add the two penalties, $613,859.18. The judgments are by consent, so the SEC's allegations of trading on non-public deal information were not tested at trial.

For the regulator's own account of the facts, read the primary documents linked above. This page summarises the structured record and does not reproduce them.

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. 2015-11-10 Litigation release published
2. 2015-12-28 Consent final judgments entered against Zhou and Liu (S.D.N.Y.)

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
• Final judgment as to Zhichen Zhou (28 Dec 2015)
• Final judgment as to Yannan Liu

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.

Related actions

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

Record added September 10, 2026. submit a correction.