The document discusses insider trading regulations in the United States and proposes reforms for Turkey. It provides definitions of insider trading and outlines who qualifies as insiders. US regulations such as Section 16, Rule 10b-5, and Rule 14e-3 are summarized. The document also compares US and Turkish regulations, enforcement, and hypothetical applications of famous US insider trading cases in Turkey. It concludes with proposals to strengthen Turkey's regulations, such as expanding the definition of insider trading and adding penalties and bounty provisions.
A review of insider trading law, with emphasis on its application to recent cases involving hedge funds. Reviews Preet Bhararaâs scorecard, the Galleon case, materiality and the âMosaic Theory," and tipping chains.
A review of insider trading law, with emphasis on its application to recent cases involving hedge funds. Reviews Preet Bhararaâs scorecard, the Galleon case, materiality and the âMosaic Theory," and tipping chains.
This talk describes the various pitfalls and sources of securities law, corporate law, fraud, and other liability crowdfunding project sponsors and their advisors may suffer. FIRA guidelines for private offerings are mentioned, as are other ways to provide full disclosure and avoid liability.
Insider Trading-Analysis of Provisions, Offences and Penalties: A presentation at Indian Institute of Corporate Affairs by Mr. Manoj Kumar, Assistant Vice President, Corporate Professionals.
Key Highlights: Who is and Insider?, Insider Regulation 2(e), explanation to connected person, regulation 2(h), What Is Price Sensitive Information, OFFICER OF A COMPANY â REGULATION 2(g), Procedure for InvestigationâŚ
There are complex securities laws that can be triggered in the business acquisition context. Because the penalties for securities violations are severe, it is always worth the time to have securities counsel review the transaction and confirm compliance with the securities laws.
Principle Based Regulation
Legislative Notes
Provides specific defenses
Introduced Trading Plans
Crucial Role for Compliance Officer
Everybody connected directly or indirectly is covered
What is Unpublished Price Sensitive Information?
What is the role of Compliance Officer in implementing this Regulations.
The Machine Learning Guide to Fine Diningraninelken
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Can insights from machine learning guide us in human decision-making? We explore this question in the context of fine dining. We will illustrate selected ML algorithms by applying them to real-life problems such as how to choose a restaurant, whether to trust server recommendations, and when to go with a favorite dish or try something new.
Rani Nelken is Director of Research at Outbrain where he works on the advanced algorithms behind the company's recommendation technology. Prior to that he was a research fellow at Harvard University. He has worked at IBM Research and several startups. He received his PhD in Computer Science from the Technion in 2001.
Steven Johnson is Grocerant GuruÂŽ at Tacoma, WA based Foodservice SolutionsÂŽ He was the Highlighted Speaker at the October 2015 SJU âFreshâ Food Summit.
Johnsonâs has been working with Restaurants, Convenience Stores, Grocery Stores, Drug Stores, and Dollar Stores to evolve the consumer commonality of Grocerant Niche Ready-2-Eat and Heat-N-Eat fresh prepared food, metrics, process while facilitating the propagation of industry best practices. The PowerPoint is his view of the Grocerant Niche
How is â#FoodPornâ changing our emotional relationship with food?Karen Fewell
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What started out as a fun piece of research into the use of the #tag '#foodporn' has resulted in a much bigger question about how we âexperience foodâ. How is the sharing of food experiences in a âsocialâ context changing our beliefs around food, eating and health and the impacting on food purchasing and consumption.
This Slideshare has been put together to accompany my submission for the #SXSW2015 Panel Picker. I hope to share research undertaken for my book #FoodPorn and open up the debate in a group discussion during the SXSW interactive event. Fingers crossed for sharing more in Texas!
Vote for the session here: http://panelpicker.sxsw.com/vote/39284
This talk describes the various pitfalls and sources of securities law, corporate law, fraud, and other liability crowdfunding project sponsors and their advisors may suffer. FIRA guidelines for private offerings are mentioned, as are other ways to provide full disclosure and avoid liability.
Insider Trading-Analysis of Provisions, Offences and Penalties: A presentation at Indian Institute of Corporate Affairs by Mr. Manoj Kumar, Assistant Vice President, Corporate Professionals.
Key Highlights: Who is and Insider?, Insider Regulation 2(e), explanation to connected person, regulation 2(h), What Is Price Sensitive Information, OFFICER OF A COMPANY â REGULATION 2(g), Procedure for InvestigationâŚ
There are complex securities laws that can be triggered in the business acquisition context. Because the penalties for securities violations are severe, it is always worth the time to have securities counsel review the transaction and confirm compliance with the securities laws.
Principle Based Regulation
Legislative Notes
Provides specific defenses
Introduced Trading Plans
Crucial Role for Compliance Officer
Everybody connected directly or indirectly is covered
What is Unpublished Price Sensitive Information?
What is the role of Compliance Officer in implementing this Regulations.
The Machine Learning Guide to Fine Diningraninelken
Â
Can insights from machine learning guide us in human decision-making? We explore this question in the context of fine dining. We will illustrate selected ML algorithms by applying them to real-life problems such as how to choose a restaurant, whether to trust server recommendations, and when to go with a favorite dish or try something new.
Rani Nelken is Director of Research at Outbrain where he works on the advanced algorithms behind the company's recommendation technology. Prior to that he was a research fellow at Harvard University. He has worked at IBM Research and several startups. He received his PhD in Computer Science from the Technion in 2001.
Steven Johnson is Grocerant GuruÂŽ at Tacoma, WA based Foodservice SolutionsÂŽ He was the Highlighted Speaker at the October 2015 SJU âFreshâ Food Summit.
Johnsonâs has been working with Restaurants, Convenience Stores, Grocery Stores, Drug Stores, and Dollar Stores to evolve the consumer commonality of Grocerant Niche Ready-2-Eat and Heat-N-Eat fresh prepared food, metrics, process while facilitating the propagation of industry best practices. The PowerPoint is his view of the Grocerant Niche
How is â#FoodPornâ changing our emotional relationship with food?Karen Fewell
Â
What started out as a fun piece of research into the use of the #tag '#foodporn' has resulted in a much bigger question about how we âexperience foodâ. How is the sharing of food experiences in a âsocialâ context changing our beliefs around food, eating and health and the impacting on food purchasing and consumption.
This Slideshare has been put together to accompany my submission for the #SXSW2015 Panel Picker. I hope to share research undertaken for my book #FoodPorn and open up the debate in a group discussion during the SXSW interactive event. Fingers crossed for sharing more in Texas!
Vote for the session here: http://panelpicker.sxsw.com/vote/39284
Foodservice - Ignoring social media is like ignoring your customers. Presente...Karen Fewell
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My presentation from #GLEE2013 about social media, customer service and foodservice. Also a sneaky peak at the name of my new book #FoodPorn which will be published summer 2014.
Presentation: Defining and leveraging your brand's social media voice
Presented by: Emily Grant, Communications Director, Plated
Eating is a shared experience amongst us all, but often times, consumable brands play it safe when defining their brand voice. This talk will discuss the importance of developing a voice that your audience both responds to and connects with, and explores how to set your brand apart from others in your field.
This is a strategy compilation on how you can use digital to get more members on a fine dining program. The example here is for the Taj epicure program which is owned by Taj hotels and resorts.
How do chefs use social media? Mars Foodservice Social Chef ReportKaren Fewell
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During October 2013, over 300 chefs took part in the Social Chef survey which Mars Foodservice ran in association with the Craft Guild of Chefs. The report was authored by Digital Blonde.
>> Nine out of ten chefs agree that social media increases footfall to an establishment.
>> Six out of ten chefs say they have bought from a supplier they have seen on social media.
>> 84.9% of chefs use social media for work with the top three networks used being Twitter, Facebook and LinkedIn.
>> Chefs most like to follow or âlikeâ other chefs, industry news and recipe sites.
>> 78.8% of chefs have attended an event because they read about it on social media.
MindShift Metrics, the Research arm of MindShift Interactive, interviewed and analyzed audiences to gain Insights into the Digital Habits of a Fine Dining Customer. This report would be beneficial for anyone in the Hospitality industry hoping to understand their customers and gain a better positioning in the market.
A majority of Restaurants are using digital to communicate and engage with their customers, but how many are actually reaping the benefits of digital to the fullest? How many are able to gain insights into customer wants and emotions?
We take you on a journey of the digital customer and their experience within Fine Dining to enable you to gain insights onto them and build up your establishment to cater to the ever-growing competition and the need for digital integration within your business.
This Report has now been made available for free after a "For Sale" Partnership with Social Samosa for 12 months.
Trade Secret and Unfair Competition - Employment IssuesQWCooper
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Protecting Trade Secrets is critical for business success.
This presentation will provide a general overview of trade secrets
and unfair competition in the work place and provide some tools for companies to safeguard trade secrets and mitigate potential risks.
Trade Secret and Unfair Competition - Employment IssuesQWCooper
Â
Protecting Trade Secrets is critical for business success.
This presentation will provide a general overview of trade secrets
and unfair competition in the work place and provide some tools for companies to safeguard trade secrets and mitigate potential risks.
Trade secret theft is a hot topic among companies today. Winston & Strawn attorneys David Enzminger, Sheryl Falk, and John Keville have successfully prosecuted trade secret cases across the US. In this dynamic presentation, these experienced attorneys shared practical advice to help you navigate your trade secret issues.
Single Asset Real Estate Cases (Series: Ethical Issues in Real Estate-Based B...Financial Poise
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Anyone involved in the field of creditors rights on a matter involving an LLC that exists solely to hold the principal asset has surely seen the play where, the night before property is scheduled to be sold at a foreclosure auction, the debtor files bankruptcy. For those not familiar with the process, doing so invokes the âAutomatic Stayâ, which prohibits the secured lender from foreclosing on the property. The debtor then attempts to make their case to the court for reorganization. But is failing to pay your mortgage really something bankruptcy was meant to solve? If the bank was going to agree to a loan modification, wouldnât the parities have worked something out by the time the sheriff sale was set? The bankruptcy code recognizes this and therefore has a section devoted to dealing with this specific kind of bankruptcyâthe Single Asset Real Estate (âSAREâ) case. The goal of this episode is to look into ethical issues surrounding these matters.
To listen to this webinar on-demand, go to: https://www.financialpoise.com/financial-poise-webinars/single-asset-real-estate-cases-2020/
Mobile Strategy considerations and 5 tips for SMB's (presentation given at Let's Talk Business June 7th, 2011)
http://www.letstalkbusiness.nsw.gov.au/app/articles/articles/view/small-business-and-mobile-marketing
Social Media - What is it, why it matters, and a 3 step action plan for business
Presentation made to the KM round table at Melbourne Zoo, August 19th, 2009
Business Valuation Principles for EntrepreneursBen Wann
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This insightful presentation is designed to equip entrepreneurs with the essential knowledge and tools needed to accurately value their businesses. Understanding business valuation is crucial for making informed decisions, whether you're seeking investment, planning to sell, or simply want to gauge your company's worth.
LA HUG - Video Testimonials with Chynna Morgan - June 2024Lital Barkan
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Have you ever heard that user-generated content or video testimonials can take your brand to the next level? We will explore how you can effectively use video testimonials to leverage and boost your sales, content strategy, and increase your CRM data.đ¤Ż
We will dig deeper into:
1. How to capture video testimonials that convert from your audience đĽ
2. How to leverage your testimonials to boost your sales đ˛
3. How you can capture more CRM data to understand your audience better through video testimonials. đ
Implicitly or explicitly all competing businesses employ a strategy to select a mix
of marketing resources. Formulating such competitive strategies fundamentally
involves recognizing relationships between elements of the marketing mix (e.g.,
price and product quality), as well as assessing competitive and market conditions
(i.e., industry structure in the language of economics).
[Note: This is a partial preview. To download this presentation, visit:
https://www.oeconsulting.com.sg/training-presentations]
Sustainability has become an increasingly critical topic as the world recognizes the need to protect our planet and its resources for future generations. Sustainability means meeting our current needs without compromising the ability of future generations to meet theirs. It involves long-term planning and consideration of the consequences of our actions. The goal is to create strategies that ensure the long-term viability of People, Planet, and Profit.
Leading companies such as Nike, Toyota, and Siemens are prioritizing sustainable innovation in their business models, setting an example for others to follow. In this Sustainability training presentation, you will learn key concepts, principles, and practices of sustainability applicable across industries. This training aims to create awareness and educate employees, senior executives, consultants, and other key stakeholders, including investors, policymakers, and supply chain partners, on the importance and implementation of sustainability.
LEARNING OBJECTIVES
1. Develop a comprehensive understanding of the fundamental principles and concepts that form the foundation of sustainability within corporate environments.
2. Explore the sustainability implementation model, focusing on effective measures and reporting strategies to track and communicate sustainability efforts.
3. Identify and define best practices and critical success factors essential for achieving sustainability goals within organizations.
CONTENTS
1. Introduction and Key Concepts of Sustainability
2. Principles and Practices of Sustainability
3. Measures and Reporting in Sustainability
4. Sustainability Implementation & Best Practices
To download the complete presentation, visit: https://www.oeconsulting.com.sg/training-presentations
Premium MEAN Stack Development Solutions for Modern BusinessesSynapseIndia
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Stay ahead of the curve with our premium MEAN Stack Development Solutions. Our expert developers utilize MongoDB, Express.js, AngularJS, and Node.js to create modern and responsive web applications. Trust us for cutting-edge solutions that drive your business growth and success.
Know more: https://www.synapseindia.com/technology/mean-stack-development-company.html
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Putting the SPARK into Virtual Training.pptxCynthia Clay
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This 60-minute webinar, sponsored by Adobe, was delivered for the Training Mag Network. It explored the five elements of SPARK: Storytelling, Purpose, Action, Relationships, and Kudos. Knowing how to tell a well-structured story is key to building long-term memory. Stating a clear purpose that doesn't take away from the discovery learning process is critical. Ensuring that people move from theory to practical application is imperative. Creating strong social learning is the key to commitment and engagement. Validating and affirming participants' comments is the way to create a positive learning environment.
Cracking the Workplace Discipline Code Main.pptxWorkforce Group
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Cultivating and maintaining discipline within teams is a critical differentiator for successful organisations.
Forward-thinking leaders and business managers understand the impact that discipline has on organisational success. A disciplined workforce operates with clarity, focus, and a shared understanding of expectations, ultimately driving better results, optimising productivity, and facilitating seamless collaboration.
Although discipline is not a one-size-fits-all approach, it can help create a work environment that encourages personal growth and accountability rather than solely relying on punitive measures.
In this deck, you will learn the significance of workplace discipline for organisational success. Youâll also learn
⢠Four (4) workplace discipline methods you should consider
⢠The best and most practical approach to implementing workplace discipline.
⢠Three (3) key tips to maintain a disciplined workplace.
Discover the innovative and creative projects that highlight my journey throu...dylandmeas
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Discover the innovative and creative projects that highlight my journey through Full Sail University. Below, youâll find a collection of my work showcasing my skills and expertise in digital marketing, event planning, and media production.
28. WHAT IF FAMOUS CASES HAPPENED IN TURKEY? ? â ? The attorney, after having learned of the law firmâs clientâs planned tender offer , purchased call options in the target company prior to the announcement of the tender offer. O'Hagan â In Turkey this case would be interpreted as manipulation. A columnist of the Wall Street Journal traded the securities he wrote about and in turn gained a profit. Carpenter â â â A companyâs former officialâs selective disclosure of insider information to an analyst giving an unfair advantage to the analyst and the analystâs clients over the public generally Dirks ? â ? A financial printer deduced the names of the target companies in takeover bids from the documents he printed. He purchased the target companyâs securities before the announcement of bids and sold them after the bids, thus making a profit. Chiarella â â â Insiders of a mine company purchased company stock on the open market with knowledge of a valuable mineral find that had not been publicly announced and made a considerable profit after the announcement. Texas Gulf Sulphur â â â A registered broker-dealer directed his customers to liquidate their holdings in Curtis-Wright stock because he had advance knowledge of a dividend cut . Cady Roberts Co. Turkey? Gain/Loss Materiality Subject Case Conviction in Turkey  Â
We will see that insiders do not have from inside the firm. The term insider encompasses may people ranging from a psychiatrist or a financial printer. ( Psychiatrist case is United States v. Willis. )
The European Council adopted the Directive on insider dealing and market manipulation (market abuse) on 3rd December 2002. The Directive is due to be implemented by Member States of its publication in the EUâs Official Journal.
However none of these views make sense. First, as Prof. Loss and Seligman noted, wage market already compensates hard worker and those who do not contribute to the company may also benefit from insider trading. Scienter is required to prove insider trading and investigations are difficult. Most of the illegal activity remains undetected. Maybe for equities trading you can say that the transaction anyway would occur. However for options for example, these information have crucial importance. You can not ignore them. Professors Loss and Seligman found that insider trading does not have any significant effect on market price and does not make prices smoother It is very difficult and costly for companies to monitor and discipline insider trading.
The purpose of §16 has two aspects According to § 16(a) these insiders file an initial report showing their holdings of all the issuerâs equity securities and if changes occur in their holdings they file a report within the first ten days of that month with the SEC and with the exchanges on which the securities are listed. §16(b) whether P and S or S and P of the issuerâs equity securities. If the issuer does not do so within 60 days, any shareholder can bring a suit against the corporate insider on behalf of the issuer. Statute of limitations is two years after the profit is realized. However short-swing profits are recoverable regardless of whether the insider actually traded on the basis of confidential information or even was in possession of any such information . Nonetheless, this conduct covered by §16(b) is not deemed to be unlawfu l and cannot cause any criminal liability or injunction of SEC.
Once bunu soyle **** §17(a) of the Securities Act and §10(b) of the Exchange Act are the general anti-fraud provisions applicable to insider cases. Although both §17(a) and Rule 10b-5 prohibit the same type of conduct, Rule 10b-5 has a broader scope. Rule 10b-5 applies to both purchases and sales of securities, whereas §17(a) applies only to sales.
unusually short and broad. There is no statutory definition of insider trading. It simply prohibits any person from doing any fraud in connection with any securities trading . The conduct should touch purchases and sales, so any decision to retain stock, although based on inside information, may not be considered under the scope of this Rule. The fraudulent act type is not specified in the rule and this interpretation is left to courts intentionally to provide flexibility in the application.
These are , as we will see, are complementing each other.
This fiduciary duty derives from common law where a company shareholder is a beneficiary of the insiderâs fiduciary obligation. Corporate insiders breach a fiduciary duty only for a personal or economic benefit. Burada bu caselerden bahsetmek lazim.
The duty may arise from a fiduciary relationship or from a relationship of trust or confidence. The traditional theory and the misappropriation theory are complementary. The traditional theory targets a corporate insiderâs breach of duty to shareholders with whom the insider transacts; the misappropriation theory prohibits trading on the basis of nonpublic information by a corporate âoutsiderâ in breach of a duty owed to the source of the information.
The rule applies regardless of whether the security is exempt from 1933 or 1934 Act or not and regardless of whether the company is publicly or closely held. Use of instrumentalities of interstate commerce, such as phones, facsimiles, or the mails must be proved. A link between the fraud and the purchase or sale Transaction causation: in a face-to-face transaction between seller and purchaser the plaintiffâs reliance can be presumed from the materiality of the omissions. âfraud on the marketâ theory for proving reliance, simply stating that the reliance requirement in a securities fraud action can be satisfied by a showing that the market price was affected by the misstatement or omission and the plaintiffâs injury is due to a purchase or sale at the then fraudulently induced market price. âloss causationâ which provides the necessary connection between the challenged conduct and the plaintiffâs pecuniary loss. A plaintiff is required to prove that a defendantâs misstatement or misconduct was at least a âsubstantial factorâ in causing a loss. As part of the Private Securities Litigation Reform Act of 1995. §21D(b)(4) of the 1934 Act now provides that loss causation is an element of a private law suit for securities fraud.
During the 1960âs, there was a substantial increase in tender offer in U.S but there were no disclosure provisions applicable to tender offers. 1968, Congress adopted the Tender Offer and Takeover of the Williams Act amendments to the Exchange Act. §14-e is one of the Williams Act amendments and it includes general antifraud provision for all tender offers However it is also quite limited in scope, since (1) it does not apply until the offeror has taken substantial steps towards making the offer and (2) both prongs of the rule are limited to information relating to a tender offer.
The SEC does not have authority to prosecute criminal actions against inside traders but it is authorized to ask the Justice Department a willful violation of Rule 10b-5 or 14e-3 is a felony that can be punished by a $1 million fine ($2.5 in the case of corporations) and up to 10 years in jail. The Insider Trading Sanctions Act (ITSA) of 1984 amended the Exchange Act by adding §21A . Since the SEC thus may seek both disgorgement and treble damages (civil penalty), an inside trader faces potential civil liability of up to four times the profit gained. The §21A penalty may be imposed on both traders and tippers and is payable into the Treasury. §21A applies only to transactions effected on an exchange or through a broker-dealer.
At first, private enforcement has evolved solely from judicial implications, even though these rules do not explicitly permit any private lawsuits. . In 1988, Congress enacted the Insider Trading and Securities Fraud Enforcement Act (ITSFEA) which amended the Exchange Act by adding §20A. SEC to pay a bounty to informers of up to 10% of any penalty collected by the SEC.
Section 15(F) requires that every registered broker dealer âestablish, maintain and enforce written policies and procedures reasonably designed âŚ. to preventâ violations of the provisions of the Exchange Act which prohibit insider trading and tipping,
However, examples of long established capital markets show that development of capital markets is usually matched with new insider trading schemes and a need for better regulations against it. beginning in the early 1980s, transnational insider trading cases have become increasingly prominent. from both national and international aspects, it is necessary to establish very comprehensive rules against insider trading.
The only difference is that CMB can only request telephone records through prosecutors and this procedure makes investigations longer.
In the case of the repetition of the acts subject to the penalties determined in this Article, the penalties given shall be increased them by one half. In order to raise the penalties, execution of the previous penalty is not a condition. â
In US : civil proceedings of SEC, criminal proceedings of DJ and private actions. Why civil enforcement : extreme difficulty to prove insider trading. What is in the mind of the trader Direct evidence of insider trading is rare. Evidence is almost entirely circumstantial. You have to examine events like â meetings in restaurants, telephone calls, relationships between people, trading patterns This is why providing civil, as well as criminal, liability is vital to the insider trading program of SEC. Proving a purely circumstantial case is easier in the civil context, Where burden of proof shifts to defendant Subpoena -> to compel witnesses to testify or to produce books, records, and other evidence.
On the other hand, a provision similar to the §16(a)âs public disclosure requirement exists in the Serial :VIII, No:20 âCommunique on Principles Regarding Public Disclosure of Material Eventsâ Article 3/H-a which states that: â major shareholders, chairman, members of BOD, general directors, assistant general directors should publicly disclose when they own more than 1% of the corp. Capital. They have to send it in writing in detail to the Board and the Exchange, every month once this amount is reached. §16 does not make short-swing transactions unlawful Current public disclosure regulations of CMB are as effective as §16 even though they donât require recovery of such profits, since the main aim of these regulations should be to deter insider trading. As opposed to SECâs injunction, cease-or-desist, disgorgement, civil penalty powers, the only penalty available to CMB other than criminal ones is prohibition of trading Similar to SEC, CMB also is authorized by law to request the correction of misleading statements and disclosure of material information.
1) Are the non-public information mentioned in these cases able to affect the Value of the security? 2) Have the defendants gained a profit or avoided a loss from this insider trading? Insider trading most often occurs when the inside information involves unexpected events crucial to assessing a companyâs value. . Information about tender offers unrelated to business developments ; rather, it is market information about the amount that some third party was willing to pay in the market for the issuerâs stock. Although Turkeyâs insider trading implications have not evolved yet to include third party insider trading and the judicial implications of such cases have not been established, due to the provision of âwith the aim of gaining benefit for himself/herself or for third parties â the convictions would also include tippers who have not traded but acted with the aim of gaining benefit for third parties who gained profit or avoided loss as a result of insider trading conduct. Manipulation under Article/A-3 where people giving and disseminating misleading, false, deceiving information and news, make comments or do not disclose information that must be disclosed, will be punished like insider trading.
Turkeyâs regulatory system is much different than U.S. and providing CMB with civil action rights or more powerful subpoena power would not result as efficient as U.S. So I proposed more article based changes. This change will allow us to grasp all insider trading cases where the information would be considered important by a reasonable shareholder It will also be able to cover insider trading relate to tender offers. According to Article 47/A of CML,CMB can impose a pecuniary punishment of between 2 billion TL and 10 billion TL on real persons and legal entities if they act in violation of the regulations, standards and forms or general and special decisions made by the Board these fees are paid to the Investorsâ Protection Fund. The amount of the fine may be stated as of up to three times profit gained or loss avoided against persons who violated Article 47/A-1 by trading in a security while in possession of material nonpublic information. Bounty : bounties to informants of up to 10% of the civil penalties recovered.
Turkeyâs regulatory system is much different than U.S. and providing CMB with civil action rights or more powerful subpoena power would not result as efficient as U.S. So I proposed more article based changes. This change will allow us to grasp all insider trading cases where the information would be considered important by a reasonable shareholder It will also be able to cover insider trading relate to tender offers. According to Article 47/A of CML,CMB can impose a pecuniary punishment of between 2 billion TL and 10 billion TL on real persons and legal entities if they act in violation of the regulations, standards and forms or general and special decisions made by the Board these fees are paid to the Investorsâ Protection Fund. The amount of the fine may be stated as of up to three times profit gained or loss avoided against persons who violated Article 47/A-1 by trading in a security while in possession of material nonpublic information. Bounty : bounties to informants of up to 10% of the civil penalties recovered.