Beginning March 18, 2026, foreign private issuers will be subject to expanded insider-trading disclosure obligations under amended Section 16(a) of the Exchange Act. Enacted through the Holding Foreign Insiders Accountable Act, the change requires FPI directors and executive officers to report equity transactions, significantly reshaping compliance obligations for non-U.S. companies trading in U.S. markets.
Authors:
Guy Ben-Ami, Partner
benami@clm.com
Steven J. Glusband, Partner
glusband@clm.com
Guy P. Lander, Partner
lander@clm.com