My understanding is that under current EU market abuse regulations trading on inside information* that you overheard on the train is still insider trading. Sharing inside information in a manner not required to fulfill your role (i.e. with an analyst if you are a regular employee, or with a specific analyst before the general analyst community if you are the management) is also a violation of MAR (dissemination) even if nobody trades on it. It is only if the information is public that you can trade on it (with an exemption for market makers).* Under MAR confidential information is not necessarily inside information, as one of the prerequisites for the information to be inside information it must be likely that it has a significant effect on the price of a financial instrument if made public.
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