Clifford Chance

Revisions to Exemptions from the Insider Trading Regulations for Transactions based on 'Agreements Prior to Obtaining Information', or 'Plans Prior to Obtaining Information', and for 'Counterbid' [Japanese Version]

30 November 2015

A new comprehensive exemption from insider trading regulations has been introduced for transactions based on an "agreement prior to obtaining information" or a "plan prior to obtaining information". The comprehensive exemption was implemented by an amendment to the Cabinet Office Ordinance concerning the Regulation of Securities Transactions, etc., which came into force on 16 September 2015. In addition, the interpretation of the exemption clause for a "counterbid" was clarified through an amendment of the Guidelines to the Financial Instruments and Exchange Act on the same day. As a result of these amendments, it is expected that certain previously restricted transactions will become more widely available.

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