Worldwide: Securities

As discussed in our prior post, the Holding Foreign Insiders Accountable Act, adopted on December 18, 2025, eliminated the exemption to the Section 16(a) reporting...

Deputy Attorney General Todd Blanche stated in accompanying remarks that the CEP is intended to "create[] incentives for companies to come forward" because companies will "know that, across the Department, they will be rewarded when they self-disclose wrongdoing, cooperate with our investigations, and remediate the misconduct."

As addressed in our prior client memo, the "Holding Foreign Insiders Accountable Act" (the "HFIAA"), which was enacted on December 18, 2025 as part of the National Defense Authorization Act for Fiscal Year 2026, requires the directors and officers of foreign private issuers ("FPIs") to make filings under Section 16(a) of the U.S. Securities Exchange Act of 1934, as amended (the "Exchange Act").