15 Apr 2025

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

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

Foreign companies accessing U.S. capital markets are required to provide audited financial statements as part of their periodic disclosure obligations. However, if the U.S. Public Company Accounting Oversight Board (PCAOB) determines that it cannot properly inspect accounting firms in a given foreign jurisdiction, it will create a list of identified issuers who, if they do not switch to an audit firm that the PCAOB can inspect, will eventually face a five-year trading prohibition. Read this practice note for up-to-date disclosure trends related to the HFCAA.

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