On October 3, the European Securities and Markets Authority (ESMA) published a Consultation Paper (the Paper) as part of the on-going review of the Market Abuse Regulation (MAR).

In the Paper, ESMA is consulting on a wide range of issues, including:

• The possible inclusion of spot foreign exchange contracts within the scope of MAR;

• The definition and delayed disclosure of inside information in different cases;

• The appropriateness of the trading prohibition and insider lists for persons discharging managerial responsibilities (PDMRs);

• A possible cross-market order book surveillance framework;

• Cum/ex and multiple withholding tax reclaim schemes; and

• Cross-border enforcement of sanctions.

The deadline for comments on the Paper is November 29.

The Paper is available here.