As previously reported in our advisory, the "Holding Foreign Insiders Accountable Act" (the HFIAA) caused directors and officers of foreign private issuers (FPIs) with equity securities registered under the US Securities Exchange Act of 1934 (the Exchange Act) to be subject to the beneficial ownership requirements under Section 16(a) of the Exchange Act (Section 16(a)) beginning on March 18, 2026. On February 27, 2026, the US Securities and Exchange Commission (the SEC) adopted final rules and amendments to implement the HFIAA. On March 5, 2026, the SEC exercised its discretionary authority under the HFIAA and issued an order granting an exemption from the beneficial ownership reporting requirements of Section 16(a) for officers and directors of certain FPIs.