The SEC has charged two senior bankers at Madrid-based Banco Santander SA and a retired Spanish judge who traded on confidential information about BHP Billiton's proposed acquisition of Potash Corp. The bank was advising on the acquisition. The three did not trade in Potash shares, but instead in contracts for difference not traded in the US but based on the underlying price of US-traded Potash stock.
http://www.sec.gov/News/PressRelease/Detail/PressRelease/1370539737461
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