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Insider Trading New Legislation

FBT Gibbons LLP

Prediction Markets Face New Compliance Era as Federal Oversight Intensifies

FBT Gibbons LLP on

Over the last several years, prediction markets (venues where traders buy and sell binary contracts tied to real‑world events) have moved from the margins of academia into a federally supervised market structure....more

McDermott Will & Schulte

Foreign private issuer officers and directors required to file with the SEC under Section 16(a) of the Securities Exchange Act of...

On December 18, 2025, the Holding Foreign Insiders Accountable Act (the Act) was enacted as part of the 2026 National Defense Authorization Act. Effective March 18, 2026, the Act eliminates an exemption from the reporting...more

Dorsey & Whitney LLP

Prepare for the Worst, and Hope for the Best: Time to Begin Preparing for Section 16 Reporting by Insiders of SEC-reporting...

Dorsey & Whitney LLP on

As you may recall, the Holding Foreign Insiders Accountable Act (the HFIAA) was signed into law on December 18, 2025. In a nutshell, this means that directors and officers of foreign private issuers whose securities are...more

Carlton Fields

Officers and Directors of Foreign Private Issuers Will Be Subject to Section 16(a) Reporting Requirements

Carlton Fields on

Buried in the defense spending bill adopted in December 2025 is a provision amending Section 16(a) to extend insider reporting obligations to certain insiders of foreign private issuers (FPIs). The provision, dubbed the...more

Sheppard Mullin Richter & Hampton LLP

Section 16(a) Reporting Obligations to Apply to Officers and Directors of Foreign Private Issuers Starting March 18, 2026

On December 18, 2025, the Holding Foreign Insiders Accountable Act (“HFIAA”) was enacted as part of the FY 2026 National Defense Authorization Act. This new law amends Section 16(a) of the Securities Exchange Act of 1934, as...more

Troutman Pepper Locke

US Insider Reporting Requirements Coming for Directors and Officers of Foreign Private Issuers

Troutman Pepper Locke on

Officers and directors of certain foreign private issuers[1] that have securities listed on a U.S. securities exchange or registered with the Securities and Exchange Commission (SEC) (for purposes of this alert, FPIs) will...more

Seward & Kissel LLP

The End of the Exemption from Filing Statements of Beneficial Share Ownership for Officers and Directors of Foreign Private...

Seward & Kissel LLP on

On December 18, 2025, President Trump signed into law the National Defense Authorization Act for Fiscal Year 2026, which contained a provision eliminating certain reporting exemptions for SEC-registered companies qualifying...more

Ballard Spahr LLP

New Law Extends Insider Reporting Requirements to Foreign Private Issuers

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President Trump signed a law late last week that amends Section 16(a)(1) of the Securities Exchange Act of 1934, as amended, to subject foreign private issuers (FPIs) to the reporting requirements for directors, officers, and...more

Morrison & Foerster LLP

Section 16 Reporting Required for Foreign Private Issuers in 2026

Morrison & Foerster LLP on

On December 18, 2025, President Trump signed into law the Holding Foreign Insiders Accountable Act (HFIAA), which eliminates a long-standing exemption that enabled foreign private issuers (FPIs) to avoid insider reporting...more

Morgan Lewis

Section 16(a) Insider Reporting Extended to Foreign Private Issuer Officers and Directors

Morgan Lewis on

The National Defense Authorization Act for the US federal government’s 2026 fiscal year was signed into law on December 18, 2025. While primarily an annual defense bill establishing the budget and expenditures of the US...more

Lowenstein Sandler LLP

SEC’s Insider Reporting Obligations Extended to Foreign Private Issuers

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On December 18, 2025, President Donald Trump signed into law the National Defense Authorization Act for Fiscal Year 2026 (NDAA).1 Included in the NDAA is Section 8103, “Disclosures by Directors, Officers, and Principal...more

Skadden, Arps, Slate, Meagher & Flom LLP

Foreign Private Issuers’ D&Os Will No Longer Be Exempt From Section 16(a) Insider Reporting Obligations

On December 18, 2025, as part of the FY 2026 National Defense Authorization Act, the Holding Foreign Insiders Accountable Act (HFIAA) was signed into law....more

Ropes & Gray LLP

Directors and Officers of FPIs Required to Begin Publicly Reporting Equity Ownership, Awards, and Transactions on March 18, 2026

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Beginning on March 18, 2026, directors and officers of foreign private issuers (“FPIs”) with equity securities registered under the Securities Exchange Act of 1934 (the “Exchange Act”) will be required to publicly file...more

DLA Piper

End Of An Era: FPIs Now Subject To Section 16 Reporting, New Requirements

DLA Piper on

For more than five decades, a significant advantage of “Foreign Private Issuer” (FPI) status was the exemption from the beneficial ownership reporting requirements and short-swing profit rules of Section 16 of the Securities...more

Wilson Sonsini Goodrich & Rosati

Foreign Private Issuer Insiders to Be Subject to Section 16(a) Reporting

On December 18, 2025, President Donald J. Trump signed the Fiscal Year 2026 National Defense Authorization Act (NDAA), which includes Section 8103, known as the “Holding Foreign Insiders Accountable Act.” The legislation...more

Jones Day

Amendments to Exchange Act Section 16(a) Extending Insider Reporting to Foreign Private Issuers Enacted

Jones Day on

President Trump has signed into law the Holding Foreign Insiders Accountable Act (the "Amendment"), which amends Section 16(a) of the Securities Exchange Act of 1934 (the "Exchange Act") to extend Section 16 "insider"...more

Mintz - Securities & Capital Markets...

Section 16 Insider Reporting to Apply to Foreign Private Issuers Beginning March 18, 2026

Effective March 18, 2026, directors and officers of U.S.-listed companies that qualify as foreign private issuers (FPIs) will be required to publicly report their equity holdings and transactions pursuant to Section 16(a) of...more

Sullivan & Worcester

Foreign Private Issuers’ Directors and Officers to Be Subject to Section 16 Reporting

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Buried in the National Defense Authorization Act for Fiscal Year 2026, is a rule change that will subject foreign private issuers registered under the Securities Exchange Act of 1934 (Exchange Act) to certain aspects of...more

Latham & Watkins LLP

EU Listing Act - Regulatory Divergence Between EU and UK MAR

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Until recently, the UK and EU post-Brexit market abuse regimes remained substantially aligned. However, the passing of the EU Listing Act reforms in 2024 has meant that UK and EU MAR have started to diverge meaningfully for...more

A&O Shearman

UK Legislates on Differentiating Risk of Domestic Politically Exposed Persons

A&O Shearman on

The Money Laundering and Terrorist Financing (Amendment) Regulations 2023, which amend the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (known as the MLRs), come into...more

A&O Shearman

UK Economic Crime Bill Introduced to Parliament

A&O Shearman on

The Economic Crime (Transparency and Enforcement) Bill has been introduced into Parliament, following the initial publication yesterday. The Bill is designed to increase transparency and enhance the U.K.'s mitigation of money...more

BCLP

Financial Services Act 2021 - changes to PDMR notifications

BCLP on

The Financial Services Act 2021 (the “Act”) has received Royal Assent and is now law. What does this mean for issuers?...more

Faegre Drinker Biddle & Reath LLP

President Biden Announces Gary Gensler as SEC Chair Nominee

On January 18, 2021, the incoming President’s Transition Team announced additional key administration post nominees, including Mr. Gary Gensler as SEC Chair. The announcement specifically provided the following regarding Mr....more

Proskauer - The Capital Commitment

New York Establishes Six-Year Statute of Limitation for Prosecution of Claims under the Martin Act

On August 25, 2019, New York Governor Andrew Cuomo signed New York State Senate Bill S6536 which established a six-year statute of limitations for the prosecution of certain crimes related to fraudulent practices in respect...more

Skadden, Arps, Slate, Meagher & Flom LLP

Hong Kong Regulatory Update - June 2015

This Hong Kong regulatory update is intended to provide a brief overview of the principal Hong Kong regulatory developments in the preceding three months relevant to companies listed or proposed to be listed on The Stock...more

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