U.S. SECURITIES AND EXCHANGE COMMISSION
Litigation Release No. 23674 / October 21, 2016
United States v. Christopher Salis, et al., Criminal Action No. 2:16-cr-148 (N.D. Ind. filed Oct. 19, 2016)
Software Executive and Two Friends Indicted for Conspiracy to Commit Insider Trading and Money Laundering
A federal grand jury in the Northern District of Indiana has indicted Christopher Salis, Douglas Miller, and Edward Miller on charges relating to insider trading, money laundering, and structuring currency transactions. The 17-count indictment also charges Douglas Miller with false statements and Edward Miller with obstruction of justice and witness harassment. All three defendants were charged earlier this year in a parallel SEC matter.
According to the indictment, returned October 19, 2016, Salis was employed as a global vice president at SAP America in August 2014 when he obtained material, nonpublic information related to SAP's intent to acquire Concur Technologies. The indictment alleges that Salis tipped his close friend, Douglas Miller, who in turn, tipped his brother, Edward Miller, and others. The Miller brothers and others allegedly purchased short-term, risky Concur call options, yielding illegal profits exceeding $500,000 after the acquisition was announced publicly on September 18, 2014. In an effort to avoid scrutiny and to evade currency transaction reporting requirements, the Miller brothers allegedly used cash, money orders, and checks to transfer some of these profits to Salis.
The criminal case against Salis and the Miller brothers is based on the same conduct alleged in an SEC complaint, which was filed on June 16, 2016. The SEC's complaint alleged that Salis, the Miller brothers, and another close friend who was not charged criminally in the grand jury's indictment, engaged in coordinated insider trading in advance of SAP's acquisition of Concur. The SEC's complaint charged the defendants with violations of Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder. The SEC's complaint also charged Salis and Douglas Miller with violations of Sections 10(b) and 14(e) of the Exchange Act and Rules 10b-5 and 14e-3 thereunder for insider trading in advance of a 2007 tender offer for Business Objects, where Salis worked at the time. The SEC's litigation is ongoing. For further information, see Litigation Release No. 23571 (June 16, 2016).
The SEC thanks the Fraud Section of the Department of Justice's Criminal Division and the United States Postal Inspection Service for their efforts in bringing this criminal action, and the Financial Industry Regulatory Authority (FINRA) for its assistance in this matter.