Key takeaways

• A new Market Abuse Regulation (“MAR”) came into effect on July 3, 2016 throughout the European Union.
• MAR imposes significant new requirements on issuers of shares, debt and other securities listed or traded on stock exchanges in the European Union.
• MAR’s reach extends not only to issuers incorporated in Europe, but to those incorporated outside as well – and includes companies who have dual share listings or have debt listings on a European Union stock exchange.
• Although U.S. high yield issuances have tended not to include a European listing in recent years, historically such listings have been popular, and U.S. companies thus may unexpectedly be caught by the new rules.
• U.S. companies with debt or shares listed or traded in Europe should be particularly mindful of the new regulations and consider whether new policies need to be put in place to comply with the requirements.