In United States v. Agrawal, the Second Circuit upheld a jury’s 2010 conviction of a former Société Générale trader under the Economic Espionage Act (EEA) and the National Stolen Property Act (NSPA). The three-judge panel unanimously affirmed the NSPA conviction, but split on whether the EEA conviction could stand in light of the Second Circuit opinion in United States v. Aleynikov, 676 F.3d 71 (2d Cir. 2012), in which the court vacated an ex-Goldman Sachs trader’s convictions under the same statutes for very similar conduct.
