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A. Insider Lists

1. VASPs must maintain complete and up-to-date lists of all Entities, including their Board, Staff, Group, advisors, accountants or other third-party agents and service providers, and those of their Group, that have or may have access to Inside Information in the course of the VASP’s business or carrying out their respective roles for the VASP [Insider List]. VASPs shall update Insider Lists accordingly while such information remains Inside Information.
2. VASPs shall retain the Insider List for a period of at least eight [8] years after it is drawn up or updated and shall provide VARA with any Insider List upon request.
3. The Insider List shall include at least—
  a. the identity of any Entity having access to Inside Information;
  b. the reason for including that Entity in the Insider List;
  c. the date and time at which that Entity obtained access to Inside Information; and
  d. the date on which the Insider List was drawn up.
4. VASPs shall update all Insider Lists promptly, including the date of the update, where—
  a. there is a change in the reason for including an Entity already on the Insider List;
  b. there is a new Entity who has access to Inside Information and needs, therefore, to be added to the Insider List; and
  c. an Entity ceases to have access to Inside Information.
  Each update shall specify the date and time when the change triggering the update occurred.
5. VASPs shall take all reasonable steps to ensure that any Entity on the Insider List acknowledges in writing the legal and regulatory duties entailed and is aware of the sanctions applicable to Insider Dealing and unlawful disclosure of Inside Information.