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Management Consulting Firm Partner Charged In Insider Trading Scheme | USAO-SDNY

Damian Williams, the United States Attorney for the Southern District of New York, and Michael J. Driscoll, Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of Investigation (“FBI”), announced today the unsealing of a criminal complaint charging PUNEET DIKSHIT, a partner in a global management consulting firm (the “Consulting Firm”), with securities fraud in connection with a scheme to commit insider trading based on material, nonpublic information regarding the upcoming public announcement that an investment bank (the “Investment Bank”) – which DIKSHIT and the Consulting Firm were advising – would be acquiring GreenSky, Inc. (“GreenSky”).  The defendant was arrested earlier today and will be presented this afternoon before U.S. Magistrate Judge Kevin N. Fox.

U.S. Attorney Damian Williams said: “As alleged, Puneet Dikshit, a consulting firm partner, exploited his access to material nonpublic information about a pending acquisition of GreenSky, Inc., to trade in GreenSky call options.  This breach of duties to his firm and its investment bank client – and violation of the law – allegedly reaped the defendant nearly half a million dollars in illegal profits.  Now Puneet Dikshit has been charged with serious felonies for his alleged conduct.”

FBI Assistant Director Michael J. Driscoll said: “As alleged, Mr. Dikshit exploited his access to material nonpublic information regarding the acquisition of Green Sky to profit from trades he made in options markets.  Actions like those we allege serve to undermine the public’s confidence in the integrity of financial markets, and, as we have demonstrated time and again, the FBI and our partners are committed to ensuring a level playing field for all investors.  Mr. Dikshit now faces significant federal charges, which should serve as a warning to others considering similar conduct.”

According to the allegations in the Complaint unsealed today in Manhattan federal court:[1]

GreenSky was a publicly traded financial technology company that provided technology to banks and merchants to make loans to consumers for home improvement, solar, healthcare, and other purposes.  GreenSky’s common stock traded under the symbol “GSKY” on the NASDAQ.

Between on or about November 2019 and on or about July 2020, and again between on or about April 2021 and on or about September 2021, the Investment Bank engaged the Consulting Firm to provide various consulting services related to its consideration of an acquisition of GreenSky and the post-acquisition integration of GreenSky.  DIKSHIT was one of the Consulting Firm partners leading these engagements.  In that role, he had access to material, nonpublic information, which he misappropriated and, in violation of the duties that he owed to the Investment Bank and the Consulting Firm, used to trade GreenSky call options. 

DIKSHIT engaged in this trading between on or about July 26, 2021, and on or about September 15, 2021 – at the same time he was leading the Consulting Firm team that was advising the Investment Bank about its potential acquisition of GreenSky.  At various times between on or about July 26, 2021, and on or about September 13, 2021, DIKSHIT purchased and sold relatively small numbers of GreenSky call options, which had expiration dates weeks or months from the time of purchase.  However, in the two days before the September 15, 2021, public announcement that the Investment Bank would be acquiring GreenSky, DIKSHIT sold all of these longer-dated GreenSky call options and purchased approximately 2,500 out-of-the-money GreenSky call options that were due to expire just a few days later, on September 17, 2021.  After the deal was announced, DIKSHIT sold these calls and realized profits of approximately $450,000.

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DIKSHIT, 40, of New York, New York, is charged with two counts of securities fraud, each of which has a maximum sentence of 20 years in prison.  The statutory maximum sentences are prescribed by Congress and provided here for informational purposes only, as any sentencing of the defendant would be determined by the judge.

Mr. Williams praised the outstanding work of the FBI.  Mr. Williams further thanked the U.S. Securities and Exchange Commission, which today filed a parallel civil action, for its assistance and cooperation in this investigation. 

This case is being handled by the Office’s Securities and Commodities Fraud Task Force.  Assistant United States Attorneys Joshua A. Naftalis and Matthew Podolsky are in charge of the prosecution.

The charges contained in the Complaint are merely accusations, and the defendant is presumed innocent unless and until proven guilty.


[1] As the introductory phrase signifies, the entirety of the text of the Complaint and the description of the Complaint set forth in this release constitute only allegations, and every fact described should be treated as an allegation.