_IANAL, but have been working in HF for the past 10 years, with quarterly compliance/regulatory trainings, where I asked numerous questions to lawyers about the

_IANAL, but have been working in HF for the past 10 years, with quarterly compliance/regulatory trainings, where I asked numerous questions to lawyers about the subject._ That would not count as insider trading. For insider trading regulation to kick in, you need to prove the information given carried substantial certainty about the outcome of the trade. A wink is definitely not substantial certainty. In your situation, the CEO would have to clearly communicate information that led to a positive trade.