The Unibanco Letters - Dual-Hatting Regulations and Global Enforcement slide image

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 35
View entire presentation