On February 27, 2026, the SEC adopted final rule and form amendments implementing the Holding Foreign Insiders Accountable Act. Our recent Client Alert discusses these new rules and the implications and key action items for foreign private issuers (FPIs) and, in particular, their officers and directors. Importantly, beginning March 18, 2026, directors and officers of FPIs with a class of equity securities registered under Section 12 of the Securities Exchange Act of 1934 will, for the first time, be required to comply with Section 16(a) insider reporting obligations.