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
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Foreign Private Issuer Insiders to Be Subject to Section 16(a) Reporting
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On December 18, 2025, President Trump signed the Fiscal Year 2026 National Defense Authorization Act (NDAA), which includes Section 8103—the “Holding Foreign Insiders Accountable Act.” This legislation alters the compliance landscape for foreign private issuers (FPIs) listed in the United States by imposing insider reporting obligations under Section 16(a) of…
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