It is certainly very suspicious that he empties his piggy banks...

It is certainly very suspicious that he empties his piggy banks of $3.5k on or around the time of the CHAS deal (once again another announcement of a deal with no anticipated revenue figures nor details of how much it is going to cost this non-performer to set up half way around the world to service these "clients"), as this deal must have been some time in the making and the MD must have been aware that the announcement was to be released on the day of the first of his trades!
If it wasn't for his position in the company, he would look like an credibly clever or lucky trader.
Strange that over the course of these two trades, the share price doubled!
Give the level of prior knowledge of the CHAS deal, the timing of the first trade and the fact that the written clearance was not acquired, I would expect some questions.