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SEC Notifies Companies of Potential Ukraine Invasion Related Disclosure Obligations

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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.

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Reagan helps companies effectively and efficiently identify and address legal compliance risk around the world. He focuses his practice on global supply chain compliance, anti-corruption and Foreign Corrupt Practices Act, fraud, business ethics, human rights and corporate compliance. He provides practical solutions on issues of trade, taxation, investment, entity registration, security, risk management and expatriate employment. He conducts investigations, risk assessments, training and due diligence on behalf of clients in Africa and other emerging markets, and is a leading thinker in the area of environmental, social and governance (ESG) and human rights-related legal obligations and emerging regulatory regimes. Reagan has written and spoken extensively on emerging compliance trends, ethics, corruption and doing business in Africa.

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Maxine is a member of the Litigation and Government Enforcement Practice Group and is a member of the Compliance and Investigations, and Dispute Resolution Practice Groups in our Washington, DC office. Maxine’s experience includes working as a summer associate at Baker McKenzie in 2020 where she focused on FCPA matters as well as trade, economic sanctions and US foreign investment restrictions. Maxine has previously interned for the Department of Justice’s National Security Division, Department of Defense’s Office of Military Commissions, and the Treasury Department’s Office of Foreign Assets Control. Prior to law school, Maxine worked for the Center on National Security at Fordham Law where she conducted counter-terrorism research.

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Maria’s practice focuses on global corporate compliance and investigations, as well as white collar criminal matters. She represents domestic and international corporate clients in a broad range of compliance matters, including criminal investigations, before the US Department of Justice, the US Securities and Exchange Commission, and other government agencies.

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