The European Union's Market Abuse Regulation (MAR)
introduced in 2016 continues to present real challenges for
businesses seeking to issue certain forms of listed debt securities
on any EU regulated market, multi-lateral trading facility or
organised trading facility. Guernsey is not part of the European
Union and has its own market abuse regime that pre-dates MAR. The
Guernsey Financial Services Commission (the GFSC) this month
adopted a concise Code of Market Conduct (the Guernsey Code).
Since the introduction of MAR the number of listings on The
International Stock Exchange (TISE) has risen dramatically. TISE is
headquartered in Guernsey which is outside the EU and is therefore
not subject to MAR. In addition TISE is a "Recognised Stock
Exchange" for HMRC purposes, making it an attractive venue for
listings. While the Guernsey Code provides helpful guidance with
respect to market abuse, it should not deter listing on TISE where
there is no reliance on TISE for