Restricted shares are secretly sold with a written non-disclosure contract all the time. The so called rules of the stock market are very rarely enforced. They find a way regardless of the security laws to do what benefits them. Remember the banks, Corzine, and the decades people reported the blatant proven illegal activity of Madoff, but there was no enforcement. That's just the ugly reality of the current era of corruption in America and could be worse in the financial markets elsewhere. However, it is legal for employees to commit stock at an agreed upon price before they are allowed to actually sell them, as many facebook employees did before it went public.