Market Trends 2024/25: Disclosure on the Holding Foreign Companies Accountable Act

Summary

This market trends 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.