Though there are no mandatory disclosure requirements related to inside information or violations of insider trading laws under US law, the DOJ’s Corporate Enforcement Policy, which incentivizes self-disclosure by offering more lenient penalties, was recently extended beyond the Foreign Corrupt Practices Act context and, accordingly, is now a factor in any self-disclosure analysis.
More topics in this series
- Awareness and Training
- Insider Trading Policies
- Insider Lists in France
- Abstention Obligation France
- Elements of an Effective Insider Trading Program
- Statutes and Official Guidance
- Disclosure Obligations – France
- Trading Preclearance Windows and Blackout Periods
- Surveillance, Testing, and Monitoring
- Information Walls
- Disclosure Obligations – UK
- Cybersecurity
- Insider Lists in the UK