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Insider trading regulations in the US and Turkey are summarized and compared. The US has the most comprehensive regulations including Section 16, Rule 10b-5 (classical and misappropriation theories), and Rule 14e-3. Turkey's only specific regulation is in the Capital Markets Law. Differences include the US focus on fiduciary duty breaches while Turkey views it as public fraud. Proposals for Turkey include clarifying materiality in laws, allowing cases without profit/loss, and adopting rules similar to bounties and Regulation FD.





























