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