Sample case

A synthetic trade checked against synthetic firm policy. The people and the company are invented.

Case 4: Filed late

Director's $30,000 sale was reported 10 trading days after the trade

Nothing about the trade itself looks suspicious. The problem is the paperwork, so a system that only weighs size and timing would let it through.

Reasons for concern

The filing arrived 10 trading days after the trade. The Section 16(a) deadline is 2.
Reporting is how the public learns about insider trades, so a late report delays that.

What could explain it

At $30,000, the trade is under the $3,000,000 single-trade limit for this role.
A late report is a paperwork problem. It does not by itself show the trade was improper.

Answer key

Flag for review

Set when the scenario was designed. A rules-based reference investigation reaches it from the evidence.

AI investigator

ClearDiffers from the answer key

Recorded live run on 2026-11-01 using gpt-4o-2024-08-06 and gpt-4o-mini-2024-07-18, costing $0.043.

What the safeguards reported

Claims check: 6 of 7 claims judged supported
Citations: 1 of 7 claims cite no evidence
Required checks: 6 of 6 run

A recorded run of the AI investigator

The conclusion and the claims below were written by the model. The checks beside them are code and a separate judging model.

What decides this case

The trade as filed

Filed 8 trading days late

SCENARIO DIRECTOR FOUR, Director of Acme Corp (ACME)

SSale1,000 shares × $30 = $30,000Jun 2, 2025

Filed: Jun 16, 2025 (Form 4), 10 trading days after the trade
Trading plan: 10b5-1 status: not established

View source result call_8oz9dadBvTVeUk2cQohcjULG

get_transaction_details({"accession_number":"SCENARIO-0000000001-25-000004"})

{
  "accession_number": "SCENARIO-0000000001-25-000004",
  "issuer_cik": "0000320193",
  "issuer_name": "Acme Corp",
  "issuer_ticker": "ACME",
  "filing_date": "2025-06-16",
  "document_type": "4",
  "reported_under_10b5_1": "unknown",
  "filing_lag_trading_days": 10,
  "rptowner_cik": "9000000004",
  "rptowner_name": "SCENARIO DIRECTOR FOUR",
  "rptowner_relationship": "Director",
  "rptowner_title": "Director",
  "transactions": [
    {
      "nonderiv_trans_sk": 1,
      "trans_date": "2025-06-02",
      "trans_code": "S",
      "trans_shares": 1000,
      "trans_priceper_share": 30,
      "trans_value": 30000,
      "trans_acquired_disp_cd": "D",
      "shrs_ownd_folwng_trans": null,
      "superseded": false,
      "superseded_by": null
    }
  ],
  "transaction_count": 1
}

Other evidence reviewed

What this role may trade

Within the limit

Largest trade: $30,000Single-trade limit: $3,000,000

Role: Director (Board)
Single-trade limit: $3,000,000
Rolling 90-day limit: $15,000,000
Blackout restrictions: High

View source result call_Ey5J1YwFkWkjHQteNELiI6xC

get_applicable_role_limits({"relationship":"Director","title":"Director"})

{
  "relationship": "Director",
  "authorization_level": "Board",
  "single_trade_limit": 3000000,
  "rolling_90d_limit": 15000000,
  "blackout_restrictions": "High",
  "currency": "USD"
}

Firm rules checked

R003Unusual Sale Pattern (Rapid Trading)Medium
R006High Volume Spike vs. Own BaselineMedium
R008Reported Rule 10b5-1 Plan (severity reducer)Low
R009Tax-Withholding Disposition (Code F, severity reducer)Low
R010Option Exercise (Code M, severity reducer)Low
R001Single Trade Limit ExceededHigh
R002Rolling 90-Day Volume ExceededHigh
R007Late Section 16(a) Filing (> 2 trading days)High
R004Large Sale After Recent AcquisitionCritical
R005Suspicious Timing Near EarningsCritical

View source result call_iAqvobMYKQEcIxZsAXVpKpDG

get_compliance_rules({})

[
  {
    "rule_id": "R003",
    "rule_name": "Unusual Sale Pattern (Rapid Trading)",
    "threshold_value": 3,
    "rule_type": "pattern",
    "severity": "Medium"
  },
  {
    "rule_id": "R006",
    "rule_name": "High Volume Spike vs. Own Baseline",
    "threshold_value": 150000,
    "rule_type": "volume_spike",
    "severity": "Medium"
  },
  {
    "rule_id": "R008",
    "rule_name": "Reported Rule 10b5-1 Plan (severity reducer)",
    "threshold_value": null,
    "rule_type": "exculpatory",
    "severity": "Low"
  },
  {
    "rule_id": "R009",
    "rule_name": "Tax-Withholding Disposition (Code F, severity reducer)",
    "threshold_value": null,
    "rule_type": "exculpatory",
    "severity": "Low"
  },
  {
    "rule_id": "R010",
    "rule_name": "Option Exercise (Code M, severity reducer)",
    "threshold_value": null,
    "rule_type": "exculpatory",
    "severity": "Low"
  },
  {
    "rule_id": "R001",
    "rule_name": "Single Trade Limit Exceeded",
    "threshold_value": null,
    "rule_type": "single_limit",
    "severity": "High"
  },
  {
    "rule_id": "R002",
    "rule_name": "Rolling 90-Day Volume Exceeded",
    "threshold_value": null,
    "rule_type": "rolling_90d_limit",
    "severity": "High"
  },
  {
    "rule_id": "R007",
    "rule_name": "Late Section 16(a) Filing (> 2 trading days)",
    "threshold_value": 2,
    "rule_type": "filing_lateness",
    "severity": "High"
  },
  {
    "rule_id": "R004",
    "rule_name": "Large Sale After Recent Acquisition",
    "threshold_value": null,
    "rule_type": "timing",
    "severity": "Critical"
  },
  {
    "rule_id": "R005",
    "rule_name": "Suspicious Timing Near Earnings",
    "threshold_value": 5,
    "rule_type": "timing",
    "severity": "Critical"
  }
]

Total traded in the 90 days before

Within the limit

Total: $30,000Rolling limit: $15,000,000

Window ending: Jun 2, 2025
Transactions counted: 1
Sale: $30,000

View source result call_UXMk8yYE34cMPP4kUooMHW9L

rolling_90d_trading_volume({"rptowner_cik":"9000000004","as_of_date":"2025-06-02"})

{
  "total_volume": 30000,
  "sales_volume": 30000,
  "purchases_volume": 0,
  "volume_by_code": {
    "S": 30000
  },
  "transaction_count": 1,
  "rptowner_cik": "9000000004",
  "window_end": "2025-06-02",
  "window_days": 90,
  "accession_numbers": [
    "SCENARIO-0000000001-25-000004"
  ]
}

Their own trading history

No history to compare

No earlier trades by this insider were found in the 180 days before this one, so there is nothing to compare it against.

View source result call_4BsPwoD9Mhnmy6HwoRexgwH6

insider_trading_baseline({"rptowner_cik":"9000000004","as_of_date":"2025-06-02"})

{
  "rptowner_cik": "9000000004",
  "as_of_date": "2025-06-02",
  "lookback_days": 180,
  "transaction_count": 0,
  "message": "No prior transactions found in this window"
}

Was news about to come out?

No blackout window

No scheduled blackout window covers Jun 2, 2025.

View source result call_VJYlXWeJ9KKqw305WbOEObwj

get_material_events({"issuer_cik":"0000320193","on_date":"2025-06-02"})

{
  "issuer_cik": "0000320193",
  "on_date": "2025-06-02",
  "in_blackout": false
}

What this role may trade

Within the limit

Largest trade: $30,000Single-trade limit: $3,000,000

Role: Director (Board)
Single-trade limit: $3,000,000
Rolling 90-day limit: $15,000,000
Blackout restrictions: High

View source result call_fmd7j960PEIf1nd3yVh48mYg

get_applicable_role_limits({"relationship":"Director","title":"Director"})

{
  "relationship": "Director",
  "authorization_level": "Board",
  "single_trade_limit": 3000000,
  "rolling_90d_limit": 15000000,
  "blackout_restrictions": "High",
  "currency": "USD"
}

Total traded in the 90 days before

Within the limit

Total: $30,000Rolling limit: $15,000,000

Window ending: Jun 2, 2025
Transactions counted: 1
Sale: $30,000

View source result call_j6Ofn0ILW0muxxNkr9CB2Zq9

rolling_90d_trading_volume({"rptowner_cik":"9000000004","as_of_date":"2025-06-02"})

{
  "total_volume": 30000,
  "sales_volume": 30000,
  "purchases_volume": 0,
  "volume_by_code": {
    "S": 30000
  },
  "transaction_count": 1,
  "rptowner_cik": "9000000004",
  "window_end": "2025-06-02",
  "window_days": 90,
  "accession_numbers": [
    "SCENARIO-0000000001-25-000004"
  ]
}

Their own trading history

No history to compare

No earlier trades by this insider were found in the 180 days before this one, so there is nothing to compare it against.

View source result call_SCsjIDRVNsqca3LSyKxUw3BV

insider_trading_baseline({"rptowner_cik":"9000000004","as_of_date":"2025-06-02"})

{
  "rptowner_cik": "9000000004",
  "as_of_date": "2025-06-02",
  "lookback_days": 180,
  "transaction_count": 0,
  "message": "No prior transactions found in this window"
}

Finding

ClearConfidence: high10b5-1 status: not established

The insider, SCENARIO DIRECTOR FOUR, conducted a sale of 1,000 shares for $30,000 on June 2, 2025. This transaction is well within the single trade limit of $3,000,000 and the rolling 90-day limit of $15,000,000 applicable to a Director. The total trading volume over the past 90 days was $30,000, which does not exceed the limits. There were no prior transactions in the 180-day lookback period, and no blackout periods were in effect. Therefore, there is no evidence of a compliance violation, and the transaction is deemed clear.

Exculpatory factors

below all thresholds (transaction 1)

Grounding: 6/7 claims supported, confidence: medium, 1 unsupported. Unverified claims remain: human review required

Claims check

The insider, SCENARIO DIRECTOR FOUR, conducted a sale of 1,000 shares for $30,000 on June 2, 2025.
The tool result confirms the sale of 1,000 shares for $30,000 on June 2, 2025.
call_8oz9dadBvTVeUk2cQohcjULG
This transaction is well within the single trade limit of $3,000,000 and the rolling 90-day limit of $15,000,000 applicable to a Director.
The tool result specifies the single trade limit of $3,000,000 and the rolling 90-day limit of $15,000,000 for a Director.
call_Ey5J1YwFkWkjHQteNELiI6xC
The total trading volume over the past 90 days was $30,000, which does not exceed the limits.
The tool result shows a total trading volume of $30,000 over the past 90 days.
call_UXMk8yYE34cMPP4kUooMHW9L
There were no prior transactions in the 180-day lookback period.
The tool result indicates no prior transactions in the 180-day lookback period.
call_4BsPwoD9Mhnmy6HwoRexgwH6
No blackout periods were in effect.
The tool result confirms that no blackout periods were in effect on the specified date.
call_VJYlXWeJ9KKqw305WbOEObwj
Therefore, there is no evidence of a compliance violation, and the transaction is deemed clear.
The claim cites no tool call, so it is unsupported.
Cites no evidence
The insider is identified as SCENARIO DIRECTOR FOUR, who holds the title of Director.
The tool result identifies the insider as SCENARIO DIRECTOR FOUR, holding the title of Director.
call_8oz9dadBvTVeUk2cQohcjULG

Process audit

Checked in code, with no AI judgement. It records how the investigation worked; it never changes the finding.

Required evidence gathered
Every required tool was called.
6 of 6 tools
Transaction details first
The first call was get_transaction_details.
Yes
Citations all real
Some claims cite no evidence at all.
Problem
Exemptions supported
The finding claims no exemption.
None claimed

Run this case yourself

Starts a new live investigation on this filing. It uses the server's model credits, and the result will differ a little from the recorded run.

Re-run this case live

Reasons for concern

What could explain it

Answer key

AI investigator

What the safeguards reported

What decides this case

The trade as filed

Other evidence reviewed

What this role may trade

Firm rules checked

Total traded in the 90 days before

Their own trading history

Was news about to come out?

What this role may trade

Total traded in the 90 days before

Their own trading history

FindingThe investigation's outcome. Clear means nothing to follow up, flag means an analyst should look, escalate means it needs urgent review.

Exculpatory factorsA fact from the filing that explains a trade innocently, such as tax withholding or an option exercise. Each one applies to a single transaction line, never to the whole filing.

Claims checkOne factual sentence pulled out of the draft so it can be checked on its own.

Process auditA check, done in code, of how the investigation got to its finding: whether it gathered all the evidence, cited only real tool calls and claimed only supported exemptions.

Run this case yourself

Finding

Exculpatory factors

Claims check

Process audit