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

On December 23, 2025, Cravath prepared a memo for its clients entitled “Section 16(a) Share Ownership and Transaction Reporting Obligations to Apply to Directors and Officers of Foreign Private Issuers from March 18, 2026.” The memo examines the Holding Foreign Insiders Accountable Act and how directors and officers of foreign private issuers will be required to comply with the share ownership and transaction reporting obligations of paragraph (a) of Section 16 of the Securities Exchange Act of 1934 within 90 days of the enactment of the 2026 U.S. National Defense Authorization Act.

Please click here to read the memo.