BEERG Newsletter - Russia: Full business disclosures required

The Staff of the US Securities and Exchange Commission’s Division of Corporation Finance released a sample comment letter that provides guidance regarding the types of disclosures that reporting companies should consider in connection with the direct or indirect impact that Russia’s invasion of Ukraine, and the international response to it, it may have on their businesses. 

Among other things, the letter identifies as possible areas of disclosure impacts suffered by companies on their business, operations, or prospects due to changes in their employee base, disruptions to their supply chain, changes in their business relationships, heightened cybersecurity risks or threats, increased volatility in the trading prices of commodities, etc