On November 19, 2024, the U.S. Department of Justice announced that Virginia resident Robert Brian Thompson, a former employee of the Federal Reserve Bank of Richmond (“FRBR”), pleaded guilty for his role in an insider trading scheme. He pleaded guilty in the Eastern District of Virginia to one count of insider trading and one count of making false statements for engaging in illegal trades and failing to disclose information about his trading to his employer. He is currently scheduled to be sentenced on March 19, 2025.
According to court documents, between October 2020 and February 2024, Thompson misappropriated confidential supervisory information (“CSI”) obtained while working as a banking supervisor and examiner at the FRBR. During the course of his employment, he allegedly obtained material nonpublic information regarding certain financial institutions under the FRBR’s supervision and, based on this information, allegedly executed 69 trades in seven different publicly traded institutions. According to the DOJ, he earned a total of approximately $770,000 in profits from the illegal trades.
According to federal prosecutors, Thompson was also required, as an employee of FRBR, to annually file a “Form for Employees Involved with Supervision and Regulation” also known as “Form D,” to disclose any assets that posed a potential conflict of interest, including any equity interest in banks that are members of the Federal Reserve System and/or bank holding companies. In an effort to conceal the insider trading scheme, Thompson allegedly filed a Form D each year, from 2020 to 2024, in which he falsely represented that he had no such assets.
The Securities and Exchange Commission also filed parallel civil charges against Thompson in the Eastern District of Virginia. The SEC’s complaint, which was filed on November 8, 2024, charged Thompson with violating the antifraud provisions of Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder. To settle the charges against him, Thompson consented to the entry of a judgment that enjoins him from committing further securities violations. Thompson also agreed to pay disgorgement, prejudgment interest, and a civil penalty to be determined by the court at a later date. The terms of settlement are subject to the court’s approval.
DOJ Press Release | Plea Agreement | Plea Agreement – Statement of Facts | SEC Press Release | SEC Complaint | SEC Unopposed Motion for Entry of Judgment