|  | 11. | The SEC brings 30 to 40 insider trading actions a year. 
 
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|  | 12. | Insider trading is, of course, extremely hard to prove. 
 
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|  | 13. | There was " a culture of insider trading," 
 
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|  | 14. | But proving insider trading allegations can be difficult, experts said. 
 
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|  | 15. | Martha Stewart stands accused of something almost routine : insider trading. 
 
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|  | 16. | They were securities fraud and other violations, not insider trading. 
 
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|  | 17. | She suggested there was at least the appearance of insider trading. 
 
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|  | 18. | He brought up the investigation of Martha Stewart for insider trading. 
 
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|  | 19. | He, like Anabtawi, likens the practice to insider trading. 
 
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|  | 20. | Wall Street in the 1980s was rife with insider trading scandals. 
 
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