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Holding Foreign Companies Accountable Act (“HFCAA”)

Dec. 1, 2021

On December 18, 2020, the Holding Foreign Companies Accountable Act became law.[1] Among other things, it requires the Commission to identify public companies that have retained a registered public accounting firm to issue an audit report where the firm has a branch or office that: (1) is located in a foreign jurisdiction, and (2) the Public Company Accounting Oversight Board (“PCAOB”) has determined that it is unable to inspect or investigate completely because of a position taken by an authority in the foreign jurisdiction. 

The Commission staff will promptly add issuers it identifies under the HFCAA to the lists below, as described in more detail in Holding Foreign Companies Accountable Act Disclosure, Release No. 34-93701. Registrants are strongly encouraged to consult the release for information on how the HFCAA will be implemented.  

This site and the information linked below comprises the relevant information related to the HFCAA and its implementation, and is where the Commission will list any Commission-Identified Issuers.

Members of the public with any questions about HFCAA implementation, or issuers who wish to submit evidence to dispute being provisionally identified as a Commission-Identified Issuer under the HFCAA, may contact the staff at

Provisional list of issuers identified under the HFCAA*

Issuer Name CIK Date provisionally identified Date by which the issuer may submit evidence disputing identification

*Issuers provisionally identified will have 15 business days to contact Commission staff at if they believe they have been incorrectly identified, and should include evidentiary support with their correspondence. Issuers are not subject to the requirements under the HFCAA Act until they have been conclusively identified.

Conclusive list of issuers identified under the HFCAA

Issuer Name CIK Year(s) identified Current trading prohibition Prior trading prohibition


[1]     Pub. L. No. 116-222, 134 Stat. 1063 (Dec. 18, 2020).

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