Market Trends 2022/23: Disclosure on the Holding Foreign Companies Accountable Act

Summary

This practice note discusses the Holding Foreign Companies Accountable Act (the ''HFCAA'') and how it affects the securities of certain foreign companies listed on U.S. national securities exchanges and over-the-counter markets. This practice note also provides sample HFCAA-related disclosures included in public filings with the U.S. Securities and Exchange Commission (the ''SEC'') and concludes with recommendations on how to enhance these disclosures.