Levoff was put on leave from Apple in July 2018 and terminated in September, the SEC lawsuit says.
"After being contacted by authorities last summer we conducted a thorough investigation with the help of outside legal experts, which resulted in termination," Apple said in a statement Wednesday.
Before his termination, Levoff was "responsible for Apple's compliance with securities laws," the SEC complaint says.
The complaint says:
In fact, Levoff shared responsibility for ensuring that employees complied with Apple's insider trading policies. On at least three occasions in 2010 and 2011, Levoff sent emails to company employees notifying them that a blackout period was about to commence and that they were prohibited from trading Apple securities for the duration of the period. In fact, Levoff sent two such emails immediately prior to his insider trading in 2011.
For example, on February 24, 2011, Levoff sent an email to Apple employees explaining that a blackout period would begin on March 1, 2011, and remain in effect "until 60 hours after earnings are released in April 2011."
The first sentence of Levoff's February 24, 2011 email stated: "REMEMBER, TRADING IS NOT PERMITTED, WHETHER OR NOT IN AN OPEN TRADING WINDOW, IF YOU POSSESS OR HAVE ACCESS TO MATERIAL INFORMATION THAT HAS NOT BEEN DISCLOSED PUBLICLY."
You can read the full SEC complaint here: