Should the SEC require companies to disclose ties to Russia? The business community weighs in

Good morning,

It’s been a week since Russian troops launched an attack on Ukraine. As Western countries continue to disrupt Russia’s economy with increased sanctions, the business community is now weighing in. 

Visa CFO Vasant Prabhu filed a Form 8-K with The U.S. Securities and Exchange Commission (SEC) on Wednesday. The company emailed me a copy of the document. It states: “Regarding the invasion of Ukraine, our number one priority is ensuring the safety and security of our colleagues and their families who are directly impacted. Visa is in the process of complying with all applicable global sanctions. As part of that compliance, we have suspended access to Visa for certain clients. It is difficult to reasonably estimate the full potential financial impact of this situation on Visa at this time.”

“In fiscal full-year 2021, total net revenues from Russia, including revenues driven by domestic as well as cross-border activities, were approximately 4% of Visa Inc. net revenues and total net revenues from Ukraine were approximately 1% of Visa Inc. net revenues,” according to the document.

Visa is among the large U.S. companies that are pausing business with Russia. Other companies include Apple, Google, Meta, Ford, and Mastercard.

Cornell Law School Professor Charles K. Whitehead believes that all public companies should be required to disclose their ties with Russia. In a new Fortune opinion piece, Whitehead writes, “Sanctions on Russia and Russian businesses will affect those who associate with them, including companies outside of Russia.”

He continues, “Regulators and shareholders alike must require companies to disclose these associations. The SEC should propose a new rule that requires public companies to disclose that risk—on each reporting company’s website and in public reports to the SEC—as well as the extent to which a company has minimized that risk following Russia’s aggression.”

Whitehead also thinks investment managers, “whose funds invest in businesses that are tied to Russia or Russian companies,” should be subjected to a similar rule. “Wholly apart from a moral interest in knowing whether a company is tied to Mr. Putin’s Russia, investors should be made aware of the risks of investing in a business whose financial well-being will be affected by sanctions,” he writes. 

Whitehead points out the potential backlash that may result from companies doing business with Russia. 

“The global outcry against Mr. Putin’s war also makes the reputational impact of associating with Russia and Russian business particularly material,” he writes. You can read more of Whitehead’s assessment here.

What are your thoughts on the topic? Let me know. 

See you tomorrow.

Sheryl Estrada

Big deal

Fidelity Investments' 2022 Money Moves Study found women 18-35 years old are starting to invest nearly one decade earlier than women ages 36 and older. In the last six months, 37% of women ages 36 and under created or updated a financial plan. Some of the factors that are holding women back from investing include career transitions, caregiving responsibilities, affordability and risk, according to Fidelity. When it comes to being proud of financial moves, women report events such as achieving important goals for themselves or family or using money to make a difference. This sentiment is higher among the younger generation (43% versus 34%).

Courtesy of Fidelity

Going deeper

The SEC and other global regulators are expected to announce new climate-related disclosure guidelines  impacting organizations. Workiva Inc. (NYSE:WK), a platform for regulatory, financial and environmental, social, and governance (ESG) reporting, and Persefoni, Inc., a climate management and accounting SaaS platform, have partnered to provide carbon disclosures to joint customers. The partnership creates a reporting solution that combines financial and ESG reporting with deeper insight around greenhouse gas accounting in accordance with the greenhouse gas protocols to track carbon emissions in Scope 1, indirect emissions in Scope 2, and upstream and downstream emissions in Scope 3, according to the companies. And allows users to integrate and transfer data between the companies’ platforms.


Sinead Gorman was named the next CFO at Shell plc, effective April 1. Current CFO Jessica Uhl will step down from her role on March 31, after five years as finance chief, and 17 years with the company. Sinead is currently EVP of finance in Shell’s global Upstream business. She started her career as a civil engineer before embarking on a finance career when she joined Shell in 1999. Since then, she has held several increasingly senior finance roles in all Shell’s major businesses, in Europe, North America and latterly globally. A British national, she will be based in London.

Alethia Young was named CFO at Graphite Bio, Inc. (Nasdaq: GRPH), a clinical-stage gene editing company. Young joins Graphite Bio from Cantor Fitzgerald, where she served as senior biotech analyst and head of research. In this newly created position, she will oversee the company’s finance, investor relations and corporate communications functions. Prior to joining Cantor Fitzgerald in 2018, Young held senior biotech analyst positions at Credit Suisse and Deutsche Bank. Earlier in her career, she was a research policy analyst and president at Marwood Group. She began her career at J.P. Morgan in the investment banking and asset management divisions.


"Bringing people together like this, and leading from the front, has inspired not only his country but also people from all over the world to join in the fight."

—David Rock, founder and CEO of the workplace consultancy NeuroLeadership Institute, on Ukrainian President Volodymyr Zelenskyy's leadership during the crisis, as told to Fortune.

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