Each element must be considered to scope requirements on firms
CSMAD applies the term 'Market Abuse’ as an
umbrella that covers 'insider dealing’, 'unlawful
disclosure of inside information’ and 'market
manipulation.’ Each of these areas is
additionally defined by European Securities
and Markets Authority (Esma) guidance, and
therefore firms should have already translated these into a
well-defined road-map that addresses changes to systems and
controls, policies and procedures, and finally training and
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