I think so, they still have to be publicly disclosed with an appropriate notice. I don't know the exact rules, but I think it typically has to be announced some

I think so, they still have to be publicly disclosed with an appropriate notice. I don't know the exact rules, but I think it typically has to be announced something like 30 days prior. May also involve restrictions around significant events such as earnings calls, quarterly events or shareholder meetings. I'm not aware of the details, as I'm just a peon in Back Office, but I do know traders pay attention to not-insider "insider" trading announcements from the SEC (yes, this pretrade information is publicly available from the SEC). I have no idea about non-US rules.