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ARTICLE · 20 NOVEMBER 2011

Registration system enhances oversight of Insider Information

Circular requires registration system for people in possession of insider information in listed companies in China.

ChinaCriminal Law

On November 16, 2010, the General Office of China's State Council promulgated a circular aimed at better detection, prevention and control of insider trading in capital markets by requiring listed companies in China to establish a registration system for people in possession of insider information (the "2010 Circular")1.   To further implement the 2010 Circular, the China Securities Regulatory Commission (the "CSRC") released the Provisions for Establishing a Registration and Administration System for Persons with Insider Information in Listed Companies, which will become effective on November, 25 2011 (the "Provisions").

If an entity that exercises control over a listed company (whether as a controlling shareholder or otherwise) and its connected party learns of or initiates any major event related to the listed company or any other event which has a major impact on the share price of the listed company, the listed company must identify all persons in possession

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