Clifford Chance

Insider Trading Law Virtually Here

29 July 2011

The Insider Trading Law that was adopted a year ago and has been gradually implemented since then is due to come into full effect on 31 July 2011.

Despite the one-year suspension the secondary legislation necessary to make the provisions of the Insider Trading Law operational was unofficially published only in mid-July 2011 and is expected to come into effect on 31 July 2011.

Recognising the virtual impossibility for the market to comply with these new regulations the Federal Service for Financial Markets has granted insiders another "grace period" in respect of a number of their duties imposed on them by the new legislation.

In this briefing we summarise the current state of play and some of the issues the market may be facing.

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