Sullivan & Cromwell Discusses SEC Exemption of Officers, Directors of Certain Foreign Private Issuers from Section 16(a) Reporting

On March 5, 2026, the U.S. Securities and Exchange Commission (the “SEC”) issued an order[1] providing conditional relief from the insider reporting requirements of Section 16(a) of the U.S. Securities Exchange Act of 1934 (the “Exchange Act”) for directors …

Paul Weiss Discusses Extension of Section 16 Reporting Obligations to Insiders of Foreign Private Issuers

On December 18, 2025, President Trump signed into law the National Defense Authorization Act for Fiscal Year 2026 (the “2026 NDAA”),which includes the Holding Foreign Insiders Accountable Act. The Holding Foreign Insiders Accountable Act amends Section 16(a) of the …