The purpose of this paper is to discuss the enactment and implementation of Russian Federal Law No. 224‐FZ dated 27 July 2010 “On Prevention of Illegitimate Use of Inside Information and Market Manipulation and on Amendments to Certain Laws of the Russian Federation”.
The paper discusses the current status of the legislation and certain issues that have yet to be resolved.
The Insider Trading Law came into effect on July 31, 2011, but a number of statutory duties of the insiders are postponed. The Federal Service for Financial Markets (FSFM) has almost accomplished the task of making the Law operational; the only missing piece of regulation is the procedure for professional participants of the securities market (PPSMs) and banks on notifying the FSFM about “suspicious” transactions of their clients. The key characteristic of the Insider Trading Law differentiating it from similar regulation in many other jurisdictions is that, as far as issuers are concerned, it operates an exhaustive list of facts, information on which qualifies as inside information.
The paper provides practical guidance from experienced Russian financial services lawyers.
