News & Analysis as of

Insider Trading Securities Exchange Act of 1934

Bradley Arant Boult Cummings LLP

In First Public Speech, SEC’s Director of Enforcement Sheds Light on Priorities and Process

Former judge Margaret Ryan became the Director of the Securities and Exchange Commission’s Division of Enforcement in September 2025. But it was not until last week, in February 2026, that she made her first public speech as...more

Morgan Lewis

Securities Enforcement Roundup – January 2026

Morgan Lewis on

In this issue of our monthly Securities Enforcement Roundup, we highlight top securities enforcement developments from January 2026. ...more

Troutman Pepper Locke

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

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Effective March 18, 2026, officers and directors of foreign private issuers that have securities listed on a U.S. securities exchange or registered with the Securities and Exchange Commission (SEC) (for purposes of this...more

Akin Gump Strauss Hauer & Feld LLP

SEC Enforcement Action Targets Insider Trading in the Pharmaceutical Industry

On December 22, 2025, the U.S. Securities and Exchange Commission (SEC) filed a complaint against several defendants for their roles in market manipulation schemes involving two pharmaceutical companies, Olema...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

Ballard Spahr LLP on

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

Ropes & Gray LLP on

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

Sullivan & Worcester on

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

Skadden, Arps, Slate, Meagher & Flom LLP

Inside the Courts – An Update From Skadden Securities Litigators - November 2025

The Middle District of Tennessee allowed significant portions of a securities class action to proceed against Shoals Technology Group, Inc. (Shoals) and certain of its executives based on allegations that they made false and...more

Goodwin

Southern District of New York Denies SEC’s Motion to Strike Affirmative Defenses of Former Cannabis Company CFO

Goodwin on

Securities Snapshot highlights notable developments in securities law, covering litigation and enforcement matters, legislation, and regulatory guidance. It is curated by lawyers in Goodwin’s Securities Litigation & SEC...more

Wilson Sonsini Goodrich & Rosati

Insider Trading Policies: A Survey of the SV150

Wilson Sonsini is pleased to present Insider Trading Policies: A Survey of the SV150, which analyzes the insider trading policies of Silicon Valley’s largest public companies....more

Morrison & Foerster LLP

Top 5 SEC Enforcement Developments for September 2025

Morrison & Foerster LLP on

Additionally, on September 26, 2025, SEC Chair Paul S. Atkins announced that the Commission will once again simultaneously evaluate settlement offers in SEC enforcement actions and requests for SEC waivers from automatic...more

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