On March 24, 2021, the US Securities and Exchange Commission (SEC) adopted interim final rules to implement portions of the Holding Foreign Companies Accountable Act (the HFCA Act), which was signed into law by President Trump on December 18, 2020. As explained in an earlier Mayer Brown Legal Update, the HFCA Act aims to address restrictions China has placed on the ability of the Public Company Accounting Oversight Board (PCAOB) to inspect or investigate PCAOB-registered public accounting firms in connection with their audits of Chinese companies by mandating certain disclosures and requiring the delisting in the United States of companies whose auditors do not (or cannot) comply with the PCAOB’s inspection rules.