I do not believe so, no. As far as I'm aware, insider trading is triggered on action, not inaction. Dumping your stock to avoid bad news or buying into stock ahead of good news = insider trading. Doing nothing based on insider info is what executives do every day.

Now, I may be wrong. If there was a strong enough case that someone avoided a loss due to not trading based on insider info, the SEC may go after your ass. But that's fairly hard to measure; they wouldn't have buy and sell trades to say, "/u/RollerRagerMD avoided $XYZ due to not trading!" because they've no idea how long you might have held onto the security before selling to get out. Maybe you would've lost $100, $15,000, $1,000,000 -- they can't say. Maybe you would've only bought one share. I suspect that they don't go after cases like this, even if they can, because they're underfunded and overworked and will go after the clear-cut cases that have actionable items that they can pinpoint as insider trading activity based on non-public knowledge.

I am not a lawyer; I may be wrong; this is my perspective alone. Don't listen to me!