Question

Under Section 22 of the Payment and Settlement Systems Act, 2007, Mr. A, an employee of a payment system operator, learns from system operations data that a particular business entity is making unusually large fund transfers to foreign accounts before a major negative announcement is likely to be made public. Mr. A shares this non-public sensitive information with his friend, Mr. B, a securities trader, suggesting potential market implications. Mr. B profits from trading on this information. Which of the following correctly determines liability under Section 22?

A Mr. A is not liable because Section 22 applies only to disclosure of customer identity, not trading information
B Mr. A is liable under Section 22 because he disclosed information whose disclosure is prohibited under that section, specifically system participant information obtained through his operational role, without legal authority or consent
C Mr. A is liable only under securities laws; the Payment and Settlement Systems Act does not address insider trading scenarios
D Mr. B is liable under Section 22 for receiving the information, while Mr. A has no liability as a mere discloser
E Disclosure is permissible if information relates to illegal activity; Mr. A's disclosure is protected as whistle-blowing
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