On October 3, the European Securities and Markets Authority (ESMA) published a Consultation Paper (the Paper) as part of the on-going review of the Market Abuse Regulation (MAR).
In the Paper, ESMA is consulting on a wide range of issues, including:
- The possible inclusion of spot foreign exchange contracts within the scope of MAR;
- The definition and delayed disclosure of inside information in different cases;
- The appropriateness of the trading prohibition and insider lists for persons discharging managerial responsibilities (PDMRs);
- A possible cross-market order book surveillance framework;
- Cum/ex and multiple withholding tax reclaim schemes; and
- Cross-border enforcement of sanctions.
The deadline for comments on the Paper is November 29.
The Paper is available here.