United States: Directors and Officers

In February, the Securities and Exchange Commission’s ("SEC's") Division of Corporation Finance issued several new or revised Compliance and Disclosure Interpretations...

As explained in our December 2025 Commentary, the HFIAA, enacted on December 18, 2025, amended Section 16(a) to require every person who is a director or an officer of an FPI with a class of equity securities registered pursuant to Section 12 of the Exchange Act to file Section 16 reports.

The Securities and Exchange Commission today adopted final rules and form amendments to reflect the requirements of the recently enacted Holding Foreign Insiders Accountable ("HFIA") Act.