Foreign private issuer directors and officers now subject to Exchange Act Section 16(a)

On December 18, 2025, President Trump signed into law the Holding Foreign Insiders Accountable Act (the Act), which amends Section 16(a) of the Securities Exchange Act of 1934 to require directors and officers of publicly traded foreign private issuers (FPIs) to file with the SEC reports of their ownership of and transactions in the issuer's equity securities. The new reporting requirement becomes effective on March 18, 2026.

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