As we wrap up our series about sanctions investigations with this post, our Global Sanctions Investigation Group has blogged about key issues that companies should keep in mind as they tackle global sanctions investigations that are inherently high-risk matters. But do you need to passively wait around for the sanctions enforcement storm to batter your company and its trade compliance team? The simple answer is a resounding no. Companies worried about sanctions compliance and potential…
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…