EFTA Document EFTA01358941

Page 6 SANCTN based on nonpublic information he learned at work.The SEC alleges that John Afriyie found out about an impending acquisition of home security company The ADT Corporation when prospective acquirer Apollo Global Management approached the Manhattan-based investment firm where he was employed and discussed potential debt financing for a public-to-private deal. Afriyie subsequently accessed several highly confidential, deal- related documents on the firm's computer network and pur