Must look into these 4 areas first:
1. Relevant Rules & regulations enforced during that material period.
2. Governance during that material period.
3. Who was/were vested with the authorities to conduct the trading?
4. National interest or pecuniary advantage?
Based on the above, the possibilities are as under:
1. Recommend criminal investigation
2. Recommend tighter housekeeping & internal surveillance.
It looks like it would be no. 2 + NFA or its equivalence.
28 June 2017.