Former California-Based Global Vice President of International Technology Company and Two Others Indicted in Scheme to Commit Insider Trading and Money Laundering

A former Palo Alto, California, based global vice president of SAP SE and two other individuals were charged in a federal indictment for their roles in a scheme to commit insider trading and money laundering that allegedly resulted in hundreds of thousands of dollars in profits.

Assistant Attorney General Leslie R. Caldwell of the Justice Department’s Criminal Division and Inspector in Charge Regina L. Faulkerson of the U.S. Postal Inspection Service’s (USPIS) Criminal Investigations Group made the announcement.

Christopher G. Salis, 39, of San Mateo, California, a former SAP global vice president; Douglas M. Miller, 40, of Dyer, Indiana; and Edward M. Miller, 43, of Munster, Indiana, were charged in a 17-count indictment returned yesterday by a federal grand jury in the Northern District of Indiana.

The indictment charges all defendants with one count of conspiracy to commit wire fraud and securities fraud, one count of conspiracy to commit money laundering and one count of conspiracy to structure currency transactions involving a financial institution for the purpose of evading the reporting requirements.  In addition, Salis is charged with four counts of wire fraud and five counts of securities fraud; Douglas Miller is charged with six counts of wire fraud, five counts of securities fraud and one count of making false statements; and Edward Miller is charged with one count of wire fraud, one count of securities fraud, one count of witness harassment and one count of obstruction of justice.

According to allegations in the indictment, while Salis was employed as a SAP global vice president, he obtained material, non-public information about SAP’s acquisition of Concur, which he disclosed to Douglas Miller in violation of a duty of confidentiality.  Douglas Miller, Edward Miller and others then allegedly purchased securities in Concur based on this information for the purposes of profiting from these transactions and returning a portion of the profits to Salis.  Following the acquisition, the indictment alleges that Douglas Miller and Edward Miller sold the securities and Douglas Miller made approximately $119,000 and Edward Miller made approximately $149,000.  Other traders who allegedly used the information profited a total of approximately $237,000.  In order to conceal the nature of the proceeds, the Millers allegedly used cash, money orders and checks to transfer some of their trading profits to Salis.  In total, Salis allegedly received nearly $90,000 from his co-conspirators.

An indictment is merely an allegation and all defendants are presumed innocent unless and until proven guilty beyond a reasonable doubt in a court of law.

USPIS investigated the case.  Trial Attorneys L. Rush Atkinson, Jennifer G. Ballantyne and Gary A. Winters of the Criminal Division’s Fraud Section are prosecuting the case.  The Securities and Exchange Commission has provided substantial assistance in this matter.