SEC Staff Highlights Review of Disclosures Pertaining to Russia’s Invasion of Ukraine: SEC Division of Corporation Finance Publishes Sample Comment Letter Regarding Disclosures Pertaining to Russia’s Invasion of Ukraine and Related Supply Chain Issues

Sullivan & Cromwell LLP - May 9, 2022

Russia’s invasion of Ukraine has had and may continue to have far-reaching impacts on the businesses of SEC-reporting companies. Companies impacted include those which: (i) have assets, operations or human capital resources located in Russia, Ukraine or Belarus, (ii) invest in those areas or hold securities that trade in those areas, (iii) are entangled in the legal and regulatory uncertainty surrounding the invasion, or (iv) rely on goods or services sourced in Russia, Ukraine or Belarus or are impacted by supply chain disruptions as a result of the invasion (including potential cybersecurity risks and other indirect operational or supply chain challenges faced by businesses with no physical operations in Russia, Ukraine or Belarus). Companies must consider how such direct or indirect impacts should be disclosed in their periodic reports to the SEC. To assist SEC-reporting companies in assessing their disclosure obligations, the SEC recently published guidance regarding certain issues that companies should consider when updating their financial disclosure and MD&A.
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