Insider Trading and Market Manipulation

If a company becomes subject to an investigation by the Securities and Exchange Surveillance Commission with regard to possible insider trading or market manipulation, the company may ultimately face large fines and criminal penalties. The Commission will have conducted a secret investigation before launching an action, so it is extremely important to be able to respond immediately after becoming aware of an investigation and to do so with knowledge and experience of the nature and scope of such investigations.


Atsumi & Sakai’s team includes lawyers with in-depth knowledge of stock trading practices - some having worked at the Securities and Exchange Surveillance Commission or as investigators at the special investigation unit of the prosecutors’ office - who are able to provide swift and appropriate responses to investigations.


The team can advise on:

  • Compliance and risk audits
  • Compliance and risk training (in-person and online)
  • Handling dawn raids
  • Responding to and managing regulatory investigations
  • Criminal defense
  • Internal investigations
  • Whistleblowing support
  • Compliance with listing rules across all stock exchanges in Japan
  • Internal insider-trading and disclosure rules
  • Employee share-trading and disciplinary rules
  • Data security

When advising foreign clients, our firm can field a team of expert Japanese lawyers and foreign lawyers who have relevant experience and bi-cultural sensitivity. Our team can do business and draft documents in Japanese, English, German, Mandarin, Hindi, Korean, and Marathi, and provides services around the clock through our global affiliated offices.



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