Insider trading in the United States, Canada and the United Kingdom

This thesis is a critical analysis of the law relating to insider trading in three common law countries. Chapter One, addresses the merits and demerits of the regulation of insider trading and presents a review of the academic literature relating to this field. In Chapters Two, Three and Four, the law of insider trading in the United States, Canada and the United Kingdom is analysed and discussed on a comparative basis. Each of these chapters is in two sections. The first section describes the regulatory system and institutions, and the second section discusses the regulation of insider trading, highlighting the critical elements of this type of regulation, such as the definition of an 'insider' and the scope of 'inside information'. It concludes with a broad discussion of the differing approaches of these countries to insider trading.