Abstract
In view of the increase in cross-border investment participation in securities markets as well as the number of potential mergers and collaborations between the securities exchanges of different countries, it is important to have an overview of the different approaches taken by various jurisdictions in regulating the securities industry. This paper contrasts the different approaches taken to regulate insider trading in several common law countries in the Asia-Pacific region, namely, Australia, Hong Kong, New Zealand, Malaysia and Singapore. Its focus is on how the regulations in these countries, in relation to their target group and the sanctions that are prescribed, reflect the different legal theories associated with insider trading. Problems associated with providing suitable sanctions that are both consistent with these theories and practicably workable are also discussed.
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