The Second Circuit held earlier this week that the criminal statute proscribing securities fraud permits convictions for insider trading without proof that the provider of material, nonpublic information received a personal benefit in exchange for that information, even though proof of a personal benefit would be required under the general securities-law statute prohibiting insider trading.  The decision in United States v. Blaszczak could ease prosecutors’ burden in obtaining convictions for insider trading by enabling the government to avoid the potentially complicated “personal benefit” issue, which has generated much litigation in recent years.  The ruling would not affect civil cases, to which the criminal statute does not apply.