On evidence establishing insider dealing in the shares of Nizhnekamskneftekhim JSC (PAO Nizhnekamskneftekhim)
The Bank of Russia’s investigation has established that Mr Artem Kh. Lyulinsky, an employee of PJSC AK BARS Bank (PAO AK BARS Bank), conducted, in July 2015, a series of transactions with ordinary shares of Nizhnekamskneftekhim JSC(further referred to as the Shares) with the use of insider information.
Mr Artem Kh. Lyulinsky was conducting these transactions under a trust agreement concluded between PJSC AK BARS Bank (Trust Management) and Ms Tatyana V. Larionova, who is married to Mr Igor V. Larionov, an insider of Nizhnekamskneftekhim JSC. Having purchased the Shares at the lowest prices prior to the announcement resulted in the price growth of the Shares, Ms Larionova succeeded in getting additional proceeds of several million rubles.
The facts established in the course of the investigation, including the terms and conditions of the trust agreement, as well as the time the money was deposited on an investment account, give grounds to believe that the client was involved when the professional securities market participant was making the investment decision.
That said, the requirements set forth in Article 6 of Federal law No.
The following actions are found to be in breach of the law:
- Conducting transactions in financial instruments to which insider information is related, including transactions conducted on behalf of a third party;
- Transmitting insider information to a person that is not included in the list of insiders due to his/her duties in line with federal laws, his/her duties in line with his/her job description or job responsibilities as per his/her labour agreement;
- Providing insider information-based recommendations to third parties forcing or making them purchase or sell their financial instruments, foreign currency and / or commodities.
The Bank of Russia took a number of measures that resulted in, among other things, corrective action at Nizhnekamskneftekhim JSC against a recurrence of similar actions in the future.
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