Section 16(a) Insider Reporting Obligations Will Apply to Foreign Private Issuers
Buried on page 2659 of the NDAA – the US$901bn defense spending bill signed into law by President Trump on December 18, 2025 – you’ll find Section 8103: “Disclosures by Directors, Officers, and Principal Stockholders” a.k.a. the “Holding Foreign Insiders Accountable Act.”



