Under the EU Market Abuse Regulation, an issuer or any person acting on behalf of an issuer or on its account must:

  • draw up a list of all persons who have access to inside information and who are employees or otherwise performing tasks through which they have access to inside information, and keep such list updated;
  • send the list to the FCA as soon as possible upon request;
  • take all reasonable steps to ensure that any persons on the insider list acknowledge in writing the legal and regulatory duties entailed and are aware of the sanctions to which they are subject; and
  • ensure that the insider list is kept for a period of five years after it is drawn up or last updated.1

Regulation 596/2014 of the European Parliament and of the Council of 16 April 2014 on market abuse (market abuse regulation) (MAR), art. 18.
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