SEC Brings Additional Charges in Insider Trading Scheme Involving NFL Player and Former Investment Banker

Litigation Release No. 24474 / May 21, 2019

Securities and Exchange Commission v. Mark "Christian" Ramsey, Civil Action No. 19-cv-2197 (E.D. Pa., filed May 21, 2019)

The Securities and Exchange Commission today charged Mark "Christian" Ramsey for participating in an insider trading scheme perpetrated by a professional football player and former investment banker previously charged by the SEC for insider trading.

In August 2018, the SEC charged Mychal Kendricks, the football player, and Damilare Sonoiki, the former investment banker, with insider trading in advance of corporate acquisitions facilitated through coded text messages and FaceTime conversations. After meeting at a party, Sonoiki allegedly began tipping Kendricks about upcoming corporate mergers that Sonoiki's investment bank was retained to advise. Kendricks allegedly traded based upon this information, generating $1.2 million in illegal profits. Kendricks and Sonoiki pled guilty in the parallel criminal case and are awaiting sentencing.

Today, the SEC charged Ramsey, a California resident, who was Kendricks' then-friend, roommate, and business partner, for his role in this scheme. According to the SEC's complaint, Kendricks enlisted Ramsey in the fall of 2014 to obtain tips from Sonoiki concerning corporate acquisition targets, and place illegal trades in Kendricks' brokerage account based upon those tips. The SEC also alleges that Kendricks made cash payments to Sonoiki in exchange for providing these illegal tips, and that Ramsey was aware of these payments, and facilitated at least one of them. Ramsey and Kendricks allegedly agreed that some of the proceeds from this trading would be used to finance Ramsey's business ventures and to settle at least one of Ramsey's debts.

The SEC's complaint, filed in federal district court in Philadelphia, charges Ramsey with primary violations of the antifraud provisions of Sections 10(b) and 14(e) of the Securities Exchange Act of 1934 and Rules 10b-5 and 14e-3 thereunder, and, in the alternative, with secondary liability pursuant to Section 20(e) of the Exchange Act for aiding and abetting Kendricks' and Sonoiki's violations of Sections 10(b) and 14(e). The SEC's complaint seeks disgorgement of allegedly ill-gotten gains, pre-judgment interest, penalties, and injunctive relief.

The U.S. Attorney's Office for the Eastern District of Pennsylvania today announced parallel criminal charges against Ramsey.

The SEC's investigation has been conducted by Rachael Clarke and Patrick McCluskey of the Market Abuse Unit in the Philadelphia Regional Office, with the assistance of John Rymas of the unit's Analysis and Detection Center. The litigation will be led by Christopher R. Kelly and supervised by Jennifer Chun Barry. The case has been supervised by Mr. Sansone and Kelly L. Gibson. The SEC appreciates the assistance of the U.S. Attorney's Office for the Eastern District of Philadelphia, the Federal Bureau of Investigation, and the Financial Industry Regulatory Authority.