Issue link: https://digital.shearman.com/i/1512772
Shearman & Sterling LLP Getting Camera Ready: Refreshing Insider Trading Policies Ahead of Mandatory Public Disclosure | 44 Dual-listed companies must thus design insider trading policies that satisfy the insider trading laws of all relevant jurisdictions, without making their policies overly complex or difficult for insiders to understand or for companies to administer. For example, a company that is subject to both U.S. laws and Europe's MAR regime may want to restrict order cancellation on the basis of MNPI generally, regardless of where the order would have been executed, and to apply a definition of relevant "information" that is broad enough to capture both U.S. and MAR concepts. CONCLUSION This article highlights just a few potential issues for companies to consider as they review their insider trading policies to get them camera ready. Many other considerations exist, and practices in the area will continue to evolve as companies grapple with issues raised by new disclosure rules and legal developments and benchmark themselves against peers whose policies will soon be disclosed. With barely a year and a half until showtime, insider trading policy review will soon be on everyone's agenda.