As discussed in this prior blog, on December 18, 2025, the Holding Foreign Insiders Accountable Act (HFIAA) removed the exemption from reporting under Section 16(a) of the Securities Exchange Act of 1934 (Exchange Act), as amended, for foreign private issuers (FPIs). 

On March 5, 2026, the United States Securities

Continue Reading SEC provides exemptive relief and issues final rules codifying Holding Foreign Insiders Accountable Act Section 16 reporting for directors and officers of foreign private issuers

The US Securities and Exchange Commission (SEC) released a joint statement on January 28, 2026 clarifying the application of federal securities laws to tokenized securities. This statement, published through the SEC’s Division of Corporation Finance, Division of Investment Management, and Division of Trading and Markets, addresses both issuer-sponsored and third

Continue Reading SEC issues guidance on tokenized securities and related developments

On January 13, 2026, the United States Securities and Exchange Commission (SEC) announced plans to conduct a comprehensive review of Regulation S-K, the central framework governing non-financial statement disclosure requirements for public companies. In a statement, SEC Chairman Paul S. Atkins emphasized that the current breadth of Regulation S-K

Continue Reading SEC proposes comprehensive reform of Regulation S-K

On September 4, 2025, the US Securities and Exchange Commission (SEC) announced the publication of its Spring 2025 Unified Agenda of Regulatory and Deregulatory Actions, which sets forth its rulemaking priorities for the next several months.

In a statement, SEC Chairman Paul Atkins noted that the agenda represents the

Continue Reading SEC rulemaking agenda focuses on crypto regulation, facilitating capital formation and easing public company reporting burdens

As discussed in our prior blog post, the US Securities and Exchange Commission (Commission) recently issued a concept release (Release) aiming to gather input on whether the criteria for designation as a foreign private issuer (FPI) should be reevaluated in light of changes to the FPI population in recent

Continue Reading Current state of play for foreign private issuers

Adopted in July 2023, the US Securities and Exchange Commission (SEC)’s cybersecurity disclosure rules require public companies to report material cybersecurity incidents on Form 8-K and to annually report on their cybersecurity risk management and governance.

However, recent developments – including SEC Chair Paul S. Atkins’s appointment in April 2025

Continue Reading The future of the SEC’s cybersecurity disclosure rules

The US Court of Appeals for the Eighth Circuit recently granted the Motion to Hold Case in Abeyance (the Motion) in Iowa v. US Securities and Exchange Commission – the case challenging the SEC’s 2024 climate disclosure rules – thereby pausing or delaying the proceedings until further order of the

Continue Reading Eighth Circuit indefinitely pauses SEC climate rule litigation: Key implications for public companies

The Securities and Exchange Commission (SEC)’s March 27, 2025 decision (the Decision) to withdraw the defense of its landmark climate-related disclosure rules adopted in March of 2024 (the Rules) did not formally pause or terminate the ongoing litigation.

On April 4, 2025, a group of 18 intervening states and the

Continue Reading SEC’s climate rule litigation update: Is it actually over?

Yesterday, March 27, 2025, the Securities and Exchange Commission (SEC) notified the US Court of Appeals for the Eighth Circuit that the SEC wishes to withdraw its defense of its landmark Climate Disclosure Rules (Climate Rules) in Iowa v. SEC, the case challenging the validity of the Climate Rules. SEC

Continue Reading SEC withdraws defense of US Climate Disclosure Rules

On February 18, 2025, President Donald J. Trump signed an Executive Order (EO), entitled, “Restoring Democracy and Accountability in Government,” which asserts greater authority over all federal agencies, including those established by Congress as independent from direct presidential control. The EO specifically lists the Securities and Exchange Commission (SEC)

Continue Reading Executive Order on federal agencies