So you're saying that for a VC, where a common approach is to invest $1 million each in 100 different startups and if just two of them turn into $50 million the

So you're saying that for a VC, where a common approach is to invest $1 million each in 100 different startups and if just two of them turn into $50 million then you break even, a fine like this is already factored into the game? I wonder what the ROI difference is between the two gambles. 100 $1 million dollar bets returns $120 million? 20 $100000 insider trades returns $5 million - $1 million fines? A 20% return is pretty good. But if it takes 2-3 years per startup, it's not as good. And it ties up $100 million. A $2 million investment that pays out $4 million within a year is much more spectacular. Edit: I am not accusing anybody of having made 20 insider trades. I am just musing about potential business models.