For some participants in the debt and credit markets, insider trading risks seem like a problem for someone else. There is some statistical basis for that assumption; the law of insider trading has been developed largely through cases involving the equity markets. There is no basis, however, for a sense of immunity. The Securities and Exchange Commission’s recent settlement involving Barclays Bank PLC and Steven J. Landzberg, a former proprietary trader for Barclays’ U.S. Distressed Debt Desk, sends a signal that the SEC is prepared to bring even novel insider trading cases in the debt markets. See SEC v. Barclays Bank PLC, Litig. Release No. 20,132 (May 30, 2007) (the "Settlement")....

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