Hwang is the founder and lead portfolio manager of Tiger Asia Partners (TAP) and Park is a trader for

the firm. TAP is participating in private placements for both Bank of China and China Construction Bank

stock, and the placement agents shared confidential information with Hwang and Park about both

companies. In the days prior to the private placement, Hwang directed Park to make short sales in each

stock. TAP earned $16.2 million by using the discounted private placement shares they received to cover

the short sales. Park’s actions were