Article examines disclosure issues that arose for public companies from two recent geopolitical crises — COVID-19, the Russian invasion of Ukraine. In connection with those geopolitical crises, the US Securities and Exchange Commission (SEC) issued guidance on COVID-19-related disclosures and sample letter focused on the conflict in Ukraine. The authors explore how the SEC's COVID-19 guidance and the sample letter provide the best available template for complying with SEC rules and regulations in connection with other potential geopolitical events, including the potential downstream risks of geopolitical tension between the People's Republic of China (mainland China) and the Republic of China (Taiwan).
"Increasing Geopolitical Risks Raise Disclosure Issues," NACD Boardtalk, July 28, 2022
*Trevor Garmey is licensed in the District of Columbia and New York. His application for the California Bar is pending.