Russia-Ukraine Disclosures And Supply Chain Issues

Supply chain issues continue to plague just about every industry and the continuing attack by Russia against the Ukraine, gives little hope of a respite in the near future.  The recent easing of congestion at the handful of U.S. ports big enough to accommodate container ships is likely more a result of inflation and a summer slowdown than effective logistical management.  Amid the ongoing difficulties, the SEC has published a sample letter to companies regarding disclosures pertaining to Russia’s invasion of the Ukraine and related supply chain issues.

SEC Sample Comment Letter

The SEC is of the view that companies should provide detailed disclosure, to the extent material or if required by a prescriptive rule, regarding: (i) direct or indirect exposure to Russia, Belarus, or Ukraine through their operations, employee base, investments in Russia, Belarus, or Ukraine, securities traded in Russia, sanctions against Russian or Belarusian individuals or entities, or legal or regulatory uncertainty associated with operating in or exiting