记者丨 杨娜娜 编辑丨姜诗蔷 一纸高达1.77亿元的罚单，揭开了又一例"老鼠仓"案件。 然而，监管通过IP地址追踪、银行账户和流水核查、电脑硬件信息比对以及交易所出具的趋同 交易信息，最终构建了完整证据链。数据显示，在2022年11月16日至2023年9月6日期间，这 些账户在沪深两市的交易与相关私募机构的操作高度趋同， 非法获利高达8857.69万元。 尽管林艺平曾在案件审理过程中提出陈述申辩意见并获部分采纳，但仍未能逃脱严厉处罚。最 终，他被没收违法所得8857.69万元，并处以等额罚款，合计被罚没金额超1.77亿元。此外， 因情节严重，林艺平还被采取五年证券市场禁入措施。 针对该IT人员为何能够长期、系统地窃取并利用未公开信息进行趋同交易的问题，深圳卓德投 资副总经理李进在接受21世纪经济报道采访时指出，从职责定位来看，量化私募旗下的科技公 司 IT人员主要负责系统搭建与技术支持，原则上不应涉及投研核心信息。私募机构若严格遵 循从业人员资格管理要求，规范项目协作机制与落实内部风控制度，特别是对策略代码、交易 数据、客户信息等核心信息实施分级授权管理，即可在相当程度上实现信息隔离。 近日，浙江证监局公布的 ...

Core Points - A significant penalty of 177 million yuan has been imposed for a case of "rat trading" involving Lin Yiping, who illegally profited over 88 million yuan through his position [1][3] - The case has drawn attention due to Lin's association with a technology company that shares a common control with two private fund managers [1][2] Summary by Sections Case Details - Lin Yiping was employed at a technology company in Hangzhou, where he was responsible for trading strategy development and risk control [2] - He accessed sensitive, non-public information from two private funds and engaged in trading activities using accounts linked to others, attempting to obscure the connection [3] Regulatory Findings - The investigation revealed that Lin's trading activities were closely aligned with the operations of the private funds, resulting in illegal profits of 88.57 million yuan [3] - The regulatory body constructed a comprehensive evidence chain through IP tracking and transaction analysis, leading to the penalties imposed [3] Industry Insights - Experts highlight systemic vulnerabilities in the management of IT personnel within private funds, suggesting that stricter controls and segregation of duties could prevent such incidents [4][9] - The case reflects a broader trend of IT and support roles being involved in insider trading, prompting calls for enhanced compliance measures across the industry [10][11] Regulatory Response - The regulatory authority's decision to impose a five-year market ban and significant financial penalties is seen as a strong message against insider trading practices [6][10] - The increasing use of technology for monitoring trading behaviors indicates a shift towards more rigorous oversight in the financial sector [7][11]

Core Viewpoint - The company has conducted a self-inspection report regarding the trading activities of insiders and incentive recipients related to the 2025 restricted stock incentive plan, confirming no misuse of insider information [1] Group 1 - The company held meetings in 2025 to review and approve the draft of the incentive plan and disclosed it [1] - The self-inspection targeted insiders and incentive recipients, querying trading activities from March 2 to September 1, 2025 [1] - During the inspection period, 8 incentive recipients engaged in trading activities, which were personal investments and did not involve insider information [1] Group 2 - No other inspected individuals were found to have engaged in trading activities [1] - The conclusion of the self-inspection indicates no evidence of insider information leakage or insider trading, with all inspected behaviors complying with regulations [1]

Core Viewpoint - The company conducted a self-examination regarding insider trading related to its 2025 Restricted Stock Incentive Plan, confirming that no insider trading occurred among the relevant parties during the specified period [1][3]. Group 1: Self-Examination Process - The self-examination covered the period from February 18, 2025, to August 18, 2025, focusing on stock trading activities of insider information personnel and incentive recipients [1]. - The examination was conducted in accordance with the relevant laws and regulations, with verification from the China Securities Depository and Clearing Corporation [1]. Group 2: Trading Activities of Insiders - During the self-examination period, only one entity, Guotai Junan Securities Co., Ltd., was found to have engaged in stock trading, while other insider information personnel did not engage in any trading activities [2]. - A total of 25 incentive recipients were identified to have traded the company's stock, but they acted based on publicly available information and independent judgment [2][3]. Group 3: Conclusion of Self-Examination - The company confirmed that appropriate confidentiality measures were in place during the planning and discussion of the incentive plan, and no insider trading was detected among the relevant parties [3]. - The findings align with the regulations set forth in the Management Measures for Equity Incentives, indicating no violations of insider trading laws [3].