The Unibanco Letters - Dual-Hatting Regulations and Global Enforcement
Insider Trading by Company Related Persons
The definition of "Insider Trading" is set forth in Article 166(1) of the FIEA:
Any person who is a "company related person" who becomes aware . . . of any material fact
relating to the business, etc. of a listed company, etc. shall not trade the specified
securities... of said listed company ... or otherwise assign or accept the same for value or
engage in the purchase or sales of securities, OTC derivative transactions ("trading”) . . . until
after said material fact . . . is publicly disclosed. The same shall apply to a person who becomes
aware of any material fact. . . for one year from the date the person ... ceases to be a company
related person.
Key Elements:
① Company Related Person/Recipient of Information from a Corporate Insider
② Material Information
③ Disclosure to Public
4 Trading in Specified Securities, Etc.
Morgan Lewis
35View entire presentation