Trading before a material announcement: how should a Saudi company review the timeline?

Checked: 2026-10-12

The practical question

A trade preceded an important announcement. Timing raises a question—but does it answer it?

Issuers, securities market participants and people with access to relevant information; this branch is not automatically shown to unrelated businesses.

Build two timelines: how information developed and circulated, and when orders were created, amended and executed. This avoids inferring knowledge from job title or personal relationships. Consider counter-evidence, including earlier instructions or information unrelated to the security traded. Separate information-use questions from order-pattern concerns requiring market expertise; email access records cannot replace trading data, or vice versa.

Alternative explanations

A documented earlier investment decision, information already public or unrelated timing; each explanation must be tested against its records.

Legal basis and verification limits

Articles 2 and 3 of the Market Conduct Regulations address manipulative or deceptive practices. Article 4 defines inside information by its connection to securities or orders, non-public status and material effect; Articles 5 and 6 address disclosure and trading. Timing alone does not establish those requirements.

• لائحة سلوكيات السوق / Market Conduct Regulations: https://cma.gov.sa/en/RulesRegulations/Regulations/Documents/Market_Conduct_Regulations_En.pdf

Review questions

• When did the information become specific, and when was it published?
• Who actually accessed it, rather than merely holding a relevant title?
• Does the order pattern raise an issue separate from information access?

Relevant records

• Disclosure versions and publication times
• Authorised information-access, meeting and communication records
• Lawfully available order records and relevant policies

Hypothetical example

Hypothetical example: a documented investment instruction predates the information under review. It is not an automatic defence, but it is relevant counter-evidence that should remain visible in the timeline.

A proposed preventive control

Is there a process for controlled access to sensitive information, disclosure records and applicable dealing reviews?

Questionnaire options: Yes, Partly, No, Unknown, Not applicable. Unknown triggers verification; Not applicable needs an applicability reason. Neither is treated as a missing control.

When professional help is useful

To request a paid legal consultation, begin with a brief non-confidential description. Identifying the parties, checking conflicts and agreeing scope and fees come before work. The consultation includes an initial review of documents within an agreed scope, a meeting to discuss the facts and questions, and a concise written summary of options, missing information and the next step in the agreed language. Internal investigations, settlement, complaints and representation are separate engagements when needed. Company representation and individual defence are separate paths subject to position and conflicts.

References

• لائحة سلوكيات السوق / Market Conduct Regulations: https://cma.gov.sa/en/RulesRegulations/Regulations/Documents/Market_Conduct_Regulations_En.pdf

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