Germany – BaFin Inside Information Use

On 28 December, BaFin issued guide on insider trading, manipulation.

  • Presentation documents as part of the BaFin issuer workshop on Dec. 11, 2017.

Insider Dealing

  • Publishing and dealing with inside information, Illegal disclosure, and sanctions.
  • Publish if issuer admitted to regulated market or MTF/OTF approved instrument.
  • Information a reasonable investor would use as a basis for investment decision.
  • Temporary postponement of publication possible, if legitimate interest of issuer.
  • Disseminate in a non-discriminatory way to wider public, free, and timely basis.
  • Ban on insider trading, recommending to third parties, and unlawful disclosures.
  • Where person has inside information, discloses to another unless normal course.

Market Manipulation

  • Discussed when the provision of ad hoc publicity, becomes market manipulation.