“To conspire to defraud the United States means primarily to cheat the government out of property or money, but it also means to interfere with or obstruct one of its lawful governmental functions by deceit, craft, or trickery. . . .”1  In the insider trading context, such a conspiracy may take the form of a scheme to obtain material, non-public information (MNPI) from a government agency with the objective of using the information as a basis to trade.2


1  Hammerschmidt v. United States, 265 U.S. 182, 188 (1924). 

2 See, e.g., Press Release, DOJ, Office of the U.S. Attorney S.D.N.Y., United States v. Blaszczak (May 4, 2018), available here.


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