I was looking for specific case law that could be used to argue that the behavior in question is unlawful, as the GP implied but did not support with facts or law.
The article you cite does not provide references to such law either; in fact, it neither has the word "fraud" nor "insider" in it. This article was about bribery, particularly of foreign officials; and the prosecutions attempted by the SEC led to consent decrees, not new securities laws. (The FCPA, however, eventually did get passed by Congress to outlaw the practice; but that is not a securities law.)
In fact, the article itself states:
> Proxmire believed that although the SEC had done all it could under the disclosure program, what was really needed was a law specifically prohibiting foreign bribery. The existing laws were not sufficient, as they addressed only the means through which a bribe might be paid, but not the act of paying a bribe itself.
