Roomy Khan, a technology executive and financial analyst who helped convict Galleon Group founder Raj Rajaratnam on fraud charges, told a group of fraud examiners last week about how she became enmeshed in the insider trading scheme.
Speaking last week at the Association of Certified Fraud Examiners’ Annual Global Fraud Conference in Las Vegas, Khan described her reversal of fortune.
“As I look at my life, it’s a tapestry of some extremely lucky breaks combined with a lot of hard work which enabled me to succeed,” she said. “However, in the end, with the reckless choices I made, I threw it all away.”
Khan described how she grew up in a middle-class family in India and then moved to the U.S. to study at Columbia University. Then she went to work in Silicon Valley in the 1980s, in the early days of the computer revolution, where she landed jobs in engineering at IBM and marketing at Intel, but secretly passed along confidential information to Rajaratnam. Later she worked on Wall Street for Galleon, where she participated in insider trading. Ultimately she ended up in prison for one year.
Khan recently told her story to “60 Minutes,” and she filled in more of the details for the ACFE conference attendees. “The drive to achieve results, which made me very successful, also became my Achilles heel,” she said. “When people engage in white collar crime, a lot of times those decisions are made secretly and alone. One is never really proud of embezzling money. However, in my case, the gathering of the inside information was part of my job training and also part of the job requirement and expectation.”
She met Rajaratnam while she was doing product marketing for Intel, and felt like she had made an instant connection. He was working as a semiconductor analyst at the investment bank Needham & Co. She kept in touch with him, hoping it would lead to a job on Wall Street. When he told her he was leaving to start his own hedge fund, Galleon, he asked her a simple, but fateful question: “How’s business?”
“I worked in marketing,” Khan recalled. “I didn’t have access to any financial data, but I had marketing data on the top customers for Intel. I used this small piece of information, combined that with the guidance the company had given on a previous conference call, and I made a mock Intel income statement for the upcoming quarter. I started sharing this information with Raj. It seemed wrong, but harmless.”
The list of the top customers changed on a daily basis, so she didn’t expect it to do much harm. “This was a perfect relationship,” said Khan. “We were engaged in animated discussions of how the stock might behave after the earnings and what the impact would be on the other companies. And also I showed him two really strong aspects about myself. The first is that I was willing to play ball, and the second is that I can take a small piece of data and translate that into powerful investment input.”
About six months later, she joined Galleon as a technology analyst in Silicon Valley. “Lucky me, I had my break,” said Khan. “Mr. Raj Rajaratnam, he used to call this the edge. This was a connotation for basically getting inside information. And he not only preached this, but he practiced it.”
She learned that on Wall Street, picking stocks depended on inside information. “Over the years of my working on Wall Street, the narrative I understood was there is no visible victim,” said Khan. “We’re not stealing from anybody. We’re not putting our hand in anyone’s pocket. And of course the ultimate: the law is messed up. But as I learned over time, disagreeing with the law doesn’t give us the right to break it. And I was about to find that out in a big way.”
By that time, she had amassed over $50 million and left Galleon. “I was working on my own, and the FBI knocked on my door,” Khan recalled. “They showed me images of me faxing Intel data to an outside office. Their opening premise was we’re looking for your cooperation against Mr. Raj, and I decided to cooperate.”
Khan worked with the federal government for a few months. In the end she paid a fine of about a quarter of a million dollars and was sentenced to a year of house arrest for wire fraud. However, the case was sealed, and Rajaratnam and her colleagues were not aware of her cooperation with the FBI. Rajaratnam, on the other hand, managed to avoid charges.
Meanwhile, Khan continued to live large despite the temporary setback. She was living in a $15 million home and said she overspent on cars and jewelry, while also overworking.
“The more I spent, the harder I worked,” she recalled. “I lived on the West Coast, so my day started at 5:30. The market opened at 6:30. I would be working in my office from 5:30 to 4:30 nonstop pretty much, and then go back in the night and do more research for the upcoming day. It was a nonstop treadmill.”
When technology stocks crashed in 2000 during the dot-com bust, she lost millions of dollars and went back to work in the hedge fund world.
“I have my cohorts who are encouraging each other to get information,” said Khan. “I’m developing my contacts again, midlevel management, senior management within the corporation, rating agencies, investment banking, you name it. It’s all about contacts and sharing them. And of course I’m back in touch with the most important contact I have on Wall Street, Raj Rajaratnam.”
Her luck was about to cave in. “In 2007, the federal government is back at me again,” she said. “The FBI knocks on my door one more time and they showed me an incriminating text between me and Raj. I said, ‘I need a lawyer.’ They handed me the phone number of my lawyer from the 1999 case. They said, ‘Talk to him and have him call us.’”
She began cooperating again with the government, meeting surreptitiously with officials. “I go to New York, they pick me up from my hotel, make me wear head scarves and big glasses, because they were really worried that I would be sighted, particularly near the courthouse area where I used to work, and somebody would get wind of this investigation,” said Khan. “But the most important thing is that they were putting a lot of pressure on me to tell the truth about everybody, not just Raj. They were threatening me with tens of years of prison time and I am having the visceral guilt now that I am toxic. Everybody I know is in trouble now because of me. It was a big struggle for me to tell on everybody. But in the end, I didn’t have a choice, and I had to do the right thing. My own culpability I had an easier time dealing with. However, admission about everyone else’s involvement was the difficult part for me.”
In 2009 the FBI arrested Rajaratnam. “This was a very surreal moment for me,” said Khan. The Wall Street Journal ran a big story on its front page the next day, but it did not give Khan’s name. However, her husband read the story and realized it referred to her, putting pressure on her marriage.
Khan pleaded guilty again, and Rajaratnam went to trial. This time he lost and was sentenced to 11 years in prison and fined over $150 million in civil and criminal penalties.
Khan regrets her actions, but points to the atmosphere on Wall Street.
“Working on Wall Street is one of the most fascinating jobs one can get,” she said. “It’s like you get up in the morning, you go to work, and you’re solving a puzzle on a daily basis. We were working in a group with camaraderie, sharing our work and trying to make the most money for our investors. However, in doing our job, we were breaking the law and I certainly was blinded between what was right and what was wrong. The decisions I made, the harm it inflicted, it’s really insurmountable, not only the harm that it caused to my family, but above it all, the breach of the rules of engagement.”
She saw it affect her marriage, her daughter and her father back in India, who read about her in the newspaper. “The breach of the faith of honesty with my own spouse, it’s hard for me to even explain how it has impacted my life,” said Khan. “As a girl who grew up in India, I came to the U.S., I went to some of the top schools, went to work for some of the best corporations, got all the breaks that I wanted. I could not have asked for more.”
Khan blames herself. “The culpability is completely mine,” she admitted. “I should have known better. I did get another chance. Even when I was breaking the law, I got another chance. Now as I’m moving forward, I’m hoping I can be part of the solution.”
Khan is giving talks now at business schools and the ACFE conference to show “the face of real temptation.”
“What do the temptations look like?” she asked. “What are the horrific consequences that you have to face when you’ve crossed the line? And above all because of my experience in the securities industry and dealing with insider trading, I’m hoping that I can highlight the gaps that perhaps may exist in compliance with the insider trading law. And maybe one day I can be a mentor to somebody again and be able to influence somebody in a positive way.”