Nvidia (NASDAQ: NVDA) has found itself under increased scrutiny following two large-scale insider trading moves last week.

Notably, Mark Stevens, the company’s director and second-largest shareholder, sold 222,500 NVDA shares on Friday, December 19, for a total of $40 million.

According to a Form 4 filing submitted on Monday, December 22, the sale was conducted at the average Nvidia stock price of $180.168, with individual transaction prices spanning from $179.96 to $180.50. 

The document also shows that Stevens gifted 258,650 NVDA shares on Thursday, December 18, at no consideration. While it has certainly fueled debate, the gift could simply be a year-end tax or estate planning commonly used by high-net-worth executives.

Even after these transactions, Stevens still owns more than 11.5 million Nvidia shares directly and approximately 15 million indirectly, through trusts. In total, his position is valued at more or less $5 billion.

While insider sales often result in increased caution, they do not necessarily reflect the company’s outlook. Indeed, Nvidia stock is trading at $188.65 at the time of writing, up nearly 9% since Stevens made his moves.

Nvidia insider trading controversy

Further speculation was fueled by principal accounting officer Donald Robertson Jr., who also sold 24,990 shares the same day, worth about $4.4 million at prices ranging from $176.907 to $180.883. 

Unlike Stevens, though, Robertson executed his transactions under a pre-arranged Rule 10b5-1 plan adopted in September, as per his own filings.

The plan, designed to reduce concerns about insider trading, allows board members to pre-schedule their shares, thus avoiding some of the flak that comes with suspiciously timed off-loads. 

The accounting officer still owns 426,860 Nvidia shares, worth roughly $80.5 million at current prices.

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