Trijya Vakil, 52, of Wynnewood, Pennsylvania, was Senior Director of Product Innovation at Elanco Animal Health when the company began quietly preparing to buy a competitor. In April 2021 she was assigned to the due diligence team for Elanco’s acquisition of Kindred Biosciences, a transaction worth about $440 million and known internally as Project Knight. What she saw covered the negotiations, the timing and the strategy, and Elanco classified it RED, the company’s designation for its most confidential material. In May 2021 she completed Elanco’s insider trading training, which prohibited employees from trading in any company’s securities on the basis of information learned at work. On May 12 she bought 500 shares of Kindred. On June 15, the day before the announcement, she told her childhood friend Neeraj Visen that the deal would be public within a day or two. He bought 38,000 shares. What followed the trading, over the next three years, is the part of this case worth reading.
The acquisition was announced on June 16, 2021 and Kindred’s share price rose approximately 46 percent. It closed on August 27, 2021, making Kindred a wholly owned Elanco subsidiary. Vakil made $2,447.50. Visen made $109,437. Both later pleaded guilty to criminal charges in the Southern District of New York, and on September 3, 2026 the Securities and Exchange Commission filed consents under which each will pay a civil penalty of $54,718, subject to court approval.
The List With His Name On It
A few months after the transaction closed, the Financial Industry Regulatory Authority opened an inquiry. This is routine. When a stock moves sharply on a merger announcement, FINRA looks at who bought it beforehand and asks the acquiring company whether it recognises any of them.
Elanco did what companies do in that position. It compiled a list of individuals who had traded Kindred stock before the announcement and circulated it to everyone who had worked on the deal, asking whether anyone recognised a name. Neeraj Visen’s name was on the list. Vakil read it and answered that she knew no one on it.
That answer did not stay inside Elanco. The company incorporated her response into what it sent back to FINRA. A false statement made to an employer during an internal review became a false statement delivered to a securities regulator, which is a materially different thing and one she had every reason to understand at the time.
Two Years Later, the FBI
The inquiry did not end there. Roughly two years after the FINRA request, the Federal Bureau of Investigation asked Vakil about her own trading in Kindred stock. According to the SEC, she made false statements to the agents.
She then did something that moved the conduct into a different category again. She contacted Visen, told him the FBI intended to record a call between the two of them, and asked him to corroborate the account she had given the agents. That is not concealment of a past act. It is an attempt to shape what a second witness would say to federal investigators who were actively building a case.
Set against the sums involved, the escalation is difficult to rationalise. Vakil made $2,447.50. To protect that, over three years, she is alleged to have lied to her employer during a regulatory review, allowed that lie to be passed to FINRA, lied to the FBI, and attempted to script a friend’s answers before a recorded call.
Trained in May, Trading in May
The sequence inside Elanco is tight enough to remove any question of misunderstanding. She joined the Project Knight team in April 2021, completed the insider trading training in May, and bought Kindred shares on May 12. The policy did not merely restrict trading in Elanco stock. It expressly prohibited trading in the securities of another company where an employee became aware of material nonpublic information about that company through their position at Elanco, which describes precisely what she did.
The RED classification carries the same weight from the other direction. Elanco did not simply treat Project Knight as confidential. It applied its highest internal tier, so everyone handling the material was told in terms what it was. Training and classification are what establish knowledge, and knowledge is the element separating insider trading from a fortunate trade.
Five Hundred Shares and Thirty-Eight Thousand
The disparity between the two positions is the oddest feature of the case. Vakil, who had the information first and directly, bought 500 shares. Visen, who had it second-hand and one day before the announcement, bought 38,000. The tippee made roughly forty-five times what the tipper did.
Visen was not a colleague, a client or a broker. He and Vakil grew up together in India, and by 2021 they messaged regularly and held weekly video calls. He had visited her in New Jersey in February 2020. At the time of the trading he was a Senior Licensing Manager at a university in Florida, and he later became Director of Licensing for Engineering at a university in Connecticut. He has never been associated with any SEC-registered entity. He had no access to Elanco and no professional reason to know anything about Kindred. What he had was a friend on the deal team who told him the day before.
What Each of Them Faced
The SEC charged both under Section 10(b) of the Securities Exchange Act and Rule 10b-5, alleging they employed a scheme to defraud, made untrue statements or omitted material facts, and engaged in acts operating as a fraud. It sought injunctions, officer and director bars, disgorgement of the combined $111,884.50 plus interest, and penalties to be set by the court.
On August 6, 2025 the court entered consent judgments permanently enjoining each from violating Section 10(b) and Rule 10b-5 and barring each from serving as an officer or director of a public company. The penalties agreed in September 2026 are identical at $54,718, which produces very different arithmetic for each. Vakil pays roughly twenty-two times what she made. Visen pays about half of his.
Conclusion
Trijya Vakil joined a deal team in April, was trained on the insider trading rule in May, and bought Kindred stock days later on information her employer had marked RED. She cleared $2,447.50, which is the least significant number in the case. She told a childhood friend the day before the announcement and he made $109,437. Then FINRA asked questions, Elanco circulated a list of pre-announcement traders, Visen’s name was on it, and she said she recognised nobody. That answer went to the regulator in Elanco’s own response. Two years later she lied to the FBI, then rang Visen to tell him the Bureau planned to record their call and to ask him to back up her account. Both pleaded guilty. Both are barred from serving as officers or directors. Both pay $54,718. The trade took a day. Defending it took three years.
