U.S. – Senate Disclosures by Foreign Insiders

U.S. – Senate Disclosures by Foreign Insiders

On 3 May 2022, Senate bill to require certain disclosures by foreign execs.

  • Senate introduced bill SB 4172, entitled the Holding Foreign Insiders Accountable Act.
  • Legislation amends SEA to address disclosures by executives of foreign private issuers.


  • Currently, executives of US publicly-traded companies must disclose any trades they make of their own company’s stocks to the SEC within two business days of the trade.
  • Executives of foreign firms, however, are not required to make such timely disclosures.
  • Foreign executives must only paper-file the disclosures to SEC long after trades made.
  • This lag means that foreign executives can keep trades private for a longer period of time, which promotes insider trading at the expense of everyday American investors.

Bill Provisions

  • Amendments would hold executives of foreign firms traded on US stock exchanges to the same disclosure requirements that executives of US-based companies follow.
  • Specifically, amend SEA Sec 16 (a) (15 USC 78p(a)(1)) to require executives of foreign firms to make electronic disclosures of trades in firm's stocks within two business days.

Legislative History

  • On 3 May 2022, Senate bill S 4172 was introduced in the Senate.