"FFS": Is that an official regulator acronym? Please explain.

1. Reasonable.

2. What specifically was the illegality in the transaction between Ruskowsky and Funk? Noted that you must have , to use your words in #1 above, something that says the action is illegal. Oh, and btw, the transaction between Ruskowsky and St Elias was non-arms length, resulting in a profit, in all likelihood based on a material undisclosed pre-existing agreement between Ruskowsky and St Elias, and to the detriment of St Elias. 

And really, if you work for a regulator, you are ripping-off your employer.