The SEC recently issued settlement orders against an investment adviser and its chief financial officer (CFO) in connection with alleged insider trading and fraudulent valuation practices by several of the adviser’s former portfolio managers. The SEC charged that, by virtue of the portfolio managers’ misconduct, the adviser violated the antifraud and compliance provisions of the federal securities laws and the CFO allegedly failed to supervise the portfolio managers. This article analyzes the terms of the settlements. For another recent enforcement action involving improper valuation, see “Hedge Fund Platinum Partners and Principals Face Civil and Criminal Proceedings From SEC and DOJ Over Alleged Fraudulent Valuation Practices and Liquidity Misrepresentations” (Jan. 12, 2017). For more on actions involving inadequate insider trading policies and procedures, see “Will Inadequate Policies and Procedures Be the Next Major Focus for SEC Enforcement Actions?” (Nov. 30, 2017). For another SEC action involving a failure to supervise, see “Despite His ‘Bad Acts,’ Issuers Beneficially Owned by Steven A. Cohen Are Not Precluded From Private Offerings Based on the Bad Actor Rule” (Jan. 21, 2016).