Correct, there are other consequences for those in posession and that get caught spreading the material non-public info.
They don't have to prove intent, only the conspiracy to disseminate. It often takes quite a while to build the case,as we saw with the SEC's action against Gendarme and their sale of billions of HRNF-issued (for cash) unregistered shares.
It looks like they knew about that company even before their latest dumping of HRNF shares. If the SEC was looking to protect investors, I would have thought they would have stopped Gendarme even before they dumped the HRNF shares. Maybe they were building a case against possible co-conspirators or even one or more of the "victim" co's themselves?
Now that Gendarme was named in the SEC actions, they are likely trying negotiate with them to get more info. I would hope that HRNF is cooperating fully with the SEC.
No one negotiates a deal for 6 billion shares-worth of warrants for huge cash payments to the company without speaking to the CEO/only board member, IMO.
