News & Analysis as of

Ukraine Disclosure Requirements

Proskauer - Regulatory & Compliance

Defence – A Sustainable Investment?  A View From The UK’s Financial Conduct Authority

On 11 March 2025, the Financial Conduct Authority (the “FCA”) published a statement clarifying that their rules, including with regards to sustainability, do not prevent investment in or financing of defence companies.  The...more

Seward & Kissel LLP

Annual Report and Shareholder Meeting Season and Other Recent SEC Developments

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This memorandum summarizes key U.S. Securities and Exchange Commission (“SEC”) and stock exchange regulatory filing deadlines, new disclosure requirements and general tips and guidance for both U.S. domestic issuers and for...more

BCLP

Time to Get Ready for the 2024 Reporting Season

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As companies look ahead to the upcoming proxy and annual report season, the SEC has generated a number of new items to add to your compliance checklist – in addition to those covered in last year's list. Those items, along...more

Seward & Kissel LLP

SEC Updates for the Upcoming 2022 Annual Reports on Form 10-K and Form 20-F

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The U.S. Securities and Exchange Commission (the “SEC”) has adopted amendments and updated disclosure requirements that are to be included in a reporting company’s annual report on Form 10-K or 20-F. The SEC has also proposed...more

White & Case LLP

Key Considerations for the 2023 Annual Reporting Season: Form 20-F and other FPI-Specific Considerations

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This memorandum outlines key considerations from White & Case's Public Company Advisory Group for foreign private issuers ("FPIs") during the 2023 annual reporting season....more

Smith Anderson

Reminders for the 2023 Annual Report and Proxy Season

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As public companies prepare their 2022 annual reports and 2023 proxy statements, they will need to contend with a host of new requirements and disclosure updates stemming from the current geopolitical and economic...more

Mintz - Privacy & Cybersecurity Viewpoints

Preparation for 2022 Fiscal Year-End SEC Filings and 2023 Annual Shareholder Meetings

Public companies initiating the year-end reporting process will need to consider, and in many cases take steps to address, a number of significant developments and issues. To assist companies in this process, Mintz has...more

White & Case LLP

MD&A disclosure in volatile times

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Current macroeconomic and geopolitical uncertainty may make it difficult for companies to know how to tackle their Management’s Discussion and Analysis of Financial Condition and Results of Operations ("MD&A") disclosure. In...more

White & Case LLP

Updating Annual Report Risk Factors: Key Developments and Drafting Considerations for Public Companies

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The Annual Report season will soon be upon us, and it is important to assess a company's risk factors at the outset and whether recent developments, including those relating to macroeconomic, geopolitical, and public health...more

Foley & Lardner LLP

Foley Manufacturing Update - October 2022

Foley & Lardner LLP on

Key Developments - The most recent article in Foley & Lardner’s Supply Chain Disruption Series shared a number of key takeaways pertaining to accurate and compliant regulatory disclosures in areas including COVID-19...more

Foley & Lardner LLP

The SEC Focuses on Supply Chain Disruptions: COVID, Russia-Ukraine Conflict and More

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As public companies across the economic spectrum strive to overcome the supply chain disruptions drastically affecting revenue and profitability, they must not lose sight of how these disruptions impact their disclosure...more

Wilson Sonsini Goodrich & Rosati

Compliance Reminder: SEC Disclosure Considerations Arising from Russia's Invasion of Ukraine

Many public companies are beginning preparations for filing quarterly reports on Form 10-Q for the second quarter of calendar 2022. As they do so, they should review and consider the U.S. Securities and Exchange Commission...more

Troutman Pepper Locke

Russia-Related Sanctions Update: SEC ‎Disclosures and New U.S. Measures

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On May 3, 2022, the U.S. Securities and Exchange Commission (“SEC”) staff issued a sample comment letter to alert public companies to potential disclosure obligations relating to the impact of Russia’s invasion of Ukraine and...more

BCLP

SEC Guidance: Disclosure Obligations Stemming from Russia’s Invasion of Ukraine

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On May 3, 2022, the SEC’s Division of Corporation Finance (“CorpFin”) issued guidance reminding companies with disclosure obligations under U.S. securities laws to be cognizant of any disclosures that may be warranted as a...more

Proskauer - Corporate Defense and Disputes

SEC Issues New Guidance Regarding Russia Sanctions and Public Company Disclosures

In response to Russian President Vladimir Putin’s decision to invade Ukraine in February, the U.S. government announced sweeping sanctions against Russia. As the conflict nears the three-month mark, businesses around the...more

Foley & Lardner LLP

SEC Directs Public Companies to Evaluate Disclosure Relating to Russia’s Invasion of Ukraine and Related Supply Chain Issues

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On May 3, 2022, 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...more

Keating Muething & Klekamp PLL

SEC Provides Sample Guidance on Disclosure of Russia-Ukraine Invasion

On May 2, 2022 the SEC’s Division of Corporation Finance issued a sample comment letter addressing disclosures companies should consider regarding Russia’s invasion of Ukraine. The SEC Staff believes companies should provide...more

Mayer Brown Free Writings + Perspectives

Sample Letter to Companies Regarding Disclosures Pertaining to Russia’s Invasion of Ukraine and Related Supply Chain Issues

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...more

Stinson - Corporate & Securities Law Blog

SEC Releases Sample Letter to Companies Regarding Disclosures Pertaining to Russia’s Invasion of Ukraine and Related Supply Chain...

The SEC has released an illustrative letter that contains sample comments that the Division of Corporation Finance may issue to companies based on their specific facts and circumstances related to Russia’s invasion of Ukraine...more

Cooley LLP

Ukrainian-American Bar Association petitions SEC for rulemaking on Russia disclosure

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We have all watched with anguish and trepidation the profound horror inflicted on Ukraine—transfixed by the brilliant and courageous fight of the Ukrainian people. That fight is also being pursued in much smaller ways, even...more

Cohen & Gresser LLP

The Economic Crime Act: What will Change for Managers of Offshore Structures

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In the early hours of 15 March 2022, the Economic Crime (Transparency and Enforcement) Act (the “Act”) came into force. The rapid passage of the Act through the UK Parliament, after years of delays, came in response to...more

Morgan Lewis

Public Companies: Consider Russia and Ukraine in Upcoming Risk Factor Disclosure

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Public companies should consider the impact of new sanctions on Russia in assessing risk factor disclosure for upcoming annual reports on Form 10-K and quarterly reports on Form 10-Q. ...more

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