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

On May 3, the staff of the Division of Corporation Finance issued an illustrative letter which provides sample comments the Division may issue to companies directly or indirectly impacted by Russia’s invasion of Ukraine and the international response thereto.

While not an exhaustive list of disclosures a company should consider, the sample comments covered the following areas:

● The direct and indirect impact of Russia’s invasion of Ukraine on a company’s business, including the impact of government actions, and investor and/or stakeholder reaction

● The impact to financial statements and related disclosures, including those related to impairments, supply chain disruption, taxes, customer contracts, etc.

● Risks, including cybersecurity, and the board of directors’ role in overseeing risks related to the invasion

● MD&A, including information on trends and uncertainties, critical accounting estimates, and supply chain disruptions

● Non-GAAP measures

● Internal controls

Our In depth, Implications of the Russian government's invasion of Ukraine, has been updated to include new Question 6.9 discussing this letter.

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