Morgan Lewis’s “Public Companies: Consider Russia and Ukraine in Upcoming Risk Factor Disclosure” reminds issuers to consider the full range of potential impacts of the Russia/Ukraine conflict, including sanctions imposed by the US and other jurisdictions against Russia and certain regions of Ukraine newly recognized by Russia as “independent,” on their business operations, in developing or updating their Risk Factors (and other relevant) disclosures.
See, e.g., these relevant February 25 Form 10-K disclosures: BlackRock (Risk Factors p23) | FMC Corporation (Risk Factors p17) | SolarWinds (Risk Factors p19) | Glatfelter (Risk Factors, MD&A, and Financials) | Northern Oil & Gas (Risk Factors p12) | Merck (Risk Factors p33) | Teledyne Technologies (Risk Factors and MD&A) | SM Energy (Risk Factors and MD&A) | Ecolab (Risk Factors and MD&A) | IFC International (Business and Risk Factors) | Bunge (Risk Factors and Financials) | Alcoa (Risk Factors p15).
See “Russia-Ukraine: Potential sanctions and SEC disclosure issues” (Wolters Kluwer); these articles: “Apple, Exxon, Ford, Others Retreat From Russia; VW Warns of Disruption” (WSJ), “Here are the private companies that have made moves against Russia” (TheHill), “Western companies head for the exit in Russia as sanctions tighten” (Reuters), “What the Russia-Ukraine Crisis Means for Businesses” (WSJ), “U.S. Companies Say They Are Monitoring Impact of Russia-Ukraine Crisis” (WSJ), “UPS and FedEx halting shipments to Russia and Ukraine” (Reuters), “Western Companies Pull Back From Russia in Response to Ukraine Invasion, Sanctions” (WSJ), and “Business leaders adjust to Ukraine conflict’s economic shocks” (FM); and additional Risk Factors resources on our Financial Reporting page.
This post first appeared in the weekly Society Alert!