No federal statute currently prohibits insider trading. Instead, prosecutors have traditionally brought insider trading cases under the Title 15 securities laws and, less frequently, the Title 18 securities fraud statute. In its recent decision United States v. Blaszczak, the Second Circuit Court of Appeals became the first court of appeals to address whether the Dirks “personal benefit” test applies to cases brought under the Title 18 securities fraud statute, holding that Dirks has no application in Title 18 cases. This Note explores the implications of United States v. Blaszczak on future insider trading prosecution strategy.