Baker McKenzie’s Global Supply Chain Compliance Blog has published a new post on a sample letter issued by the U.S. Securities and Exchange Commission (“SEC”) Division of Corporation Finance advising companies on their potential need to disclose direct and indirect impact of Russia’s invasion of Ukraine and the related international response on their operations. The sample letter does not create any new disclosure obligations, though it indicates that companies should consider the various direct and indirect impacts of the invasion on their operations and supply chains and determine whether any of these impacts are material and thus should be disclosed.
The new blog post, “SEC Notifies Companies of Potential Ukraine Invasion Related Disclosure Obligations,” can be found here.