International Journal For Multidisciplinary Research

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Insider Trading Laws in India, the United States, and China: A Comparative Analysis of Laws and Markets’ Integrity

Author(s) Mr. Saurabh Ravindra Rajput
Country India
Abstract Insider trading is a issues among that have attracted extensive attention in the field of securities regulation in the modern world. this practice directly affects the integrity of the securities markets, as like the trust and confidence of investors in the securities markets and the access to information for all participants in the securities market process and regulation. Every country applies specific regulations and laws related to insider trading, that are determined by several factors including the country’s economy, legal system and securities markets characteristics different countrys. The following paper presents a comparative legal analysis of insider trading laws and regulation in India, the United States and China. In this paper, the author discusses the specific laws and regulation of insider trading legislation in the different countries mentioned above.
The comparative legal analysis involves analysis of insider trading through three regulatory models namely, US Model which is characterized by the idea of fiduciary duty which are highest legal standard which care of individual or entity which tells a trusted advisor how to act (selflessly and carefully), and antifraud principle which sets the baseline for what they absolutely cannot do (lie, cheat, or steal), these principle depends largely on jurisdiction and the specific relationship ,the Rule 10b-5 of the Securities Exchange Act of 1934), the idea of parity of information under the SEBI (Prohibition of Insider Trading) Regulations, 2015 in India and the securities market regulation in the China. The governing trust funds generally in impose of stricter, proactive fiduciary duties that those regulating regular broker-dealers.
Keywords Insider Trading, Securities and Exchange Board of India (SEBI), Securities and Exchange Commission (SEC), China Securities Regulatory Commission (CSRC), Securities Regulation, Unpublished Price Sensitive Information (UPSI), Fiduciary Duty, antifraud principle, Comparative Law.
Field Sociology > Administration / Law / Management
Published In Volume 8, Issue 3, May-June 2026
Published On 2026-06-04
DOI https://doi.org/10.36948/ijfmr.2026.v08i03.80224
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CrossRef DOI prefix of IJFMR is 10.36948/ijfmr

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