It turns out he was the one who was buying and selling shares illegally, according to the USA authorities.
The U.S. Securities and Exchange Commission says the executive who was in charge of Apple's insider trading policy himself committed insider trading in 2015 and 2016 -in one case, selling off about $10 million in Apple stock in advance of a quarterly earnings announcement. The illegal investments led to about US$227,000 in profits, while allowing him to avoid US$377,000 of losses, according to the USA attorney's office in Newark, New Jersey, which filed criminal charges against Levoff.
"For example, in July 2015 Levoff received material nonpublic financial data that showed Apple would miss analysts' third quarter estimates for iPhone unit sales". Between July 17 and July 21, when Apple published its quarterly earnings report, he sold almost his entire holding of Apple stock, totaling almost $10 million. When the company reported earnings, its shares plunged more than 4 per cent. Levoff avoided losing about US$345,000, the SEC said.
The biggest trade came in July 2015 when he sold $10m of his own Apple stock - nearly everything he had - to avoid losing money because he found out ahead of time that Apple's results were worse than the market anticipated, the SEC claims. He was also chair of the company's Disclosure Committee - where he was was privy to "material nonpublic information about Apple's financial results" - from September 2008 until July 2018, when he was placed on leave. Levoff's alleged misconduct was relatively simple for someone who worked at a cutting-edge technology giant.
Other trades based on insider information helped him make money, it is claimed, with the SEC saying that over two years he benefited to the tune of $382,000.
As the head of Apple's corporate law office, Levoff was in charge of ensuring that employees complied with the company's policy on insider trading, the SEC said in the compliant. He was sacked from Apple in September 2018. Over his decade long career at Apple, he was one of the company's most senior executives, reporting directly to the company's general counsel.
Apple fired him previous year after being contacted by authorities and conducting an internal investigation. It also seeks a monetary penalty against Levoff, and to bar him from serving as an officer or director of a public company in the future.