The Netherlands Authority for the Financial Markets ("AFM") has revised its brochure on insider trading. The primary amendment concerns the obligation of insiders to notify transactions in financial instruments issued by their own institution to the AFM.
At the time the Financial Markets Supervision Act ("FMSA") was drafted, this notification requirement did not apply to an issuing institution established in the Netherlands which has issued financial instruments admitted to trading on a system in a non-member state comparable with a regulated market or multilateral facility. The Financial Markets Amendment Act 2012 has remedied this omission, which explains why the AFM amended its brochure on this point.
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