On May 3, the SEC’s Division of Corporation Finance issued guidance through the release of a sample comment letter of public reporting companies’ potential disclosure obligations related to “the direct or indirect impact that Russia’s invasion of Ukraine and the international response have had or may have on their business.” The SEC identified the following broad areas as those that reporting companies should consider for disclosure to the extent material or otherwise required:
- Direct or indirect exposure to Russia, Belarus, or Ukraine through operations, employees, investments, securities, etc.;
- Direct or indirect reliance on goods or services sourced in Russia or Ukraine or, in some cases, in countries supportive of Russia;
- Actual or potential supply chain disruptions; or
- Business relationships, connections to, or assets in Russia, Belarus, or Ukraine.
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