ARTICLE · 16 OCTOBER 2023

SEC Disclosure Considerations Arising From The Israel-Hamas War

Goodwin Procter LLP

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Registrants may have disclosure obligations under the federal securities laws related to the direct or indirect impact of Israel's declaration...

United StatesGovernment, Public Sector

Jeffrey Letalien

Jacqueline R. Kaufman

Registrants may have disclosure obligations under the federal securities laws related to the direct or indirect impact of Israel's declaration of war on Hamas, a U.S. designated Foreign Terrorist Organization,¹ and current armed conflict in Israel and the Gaza Strip (the “War”).

Given the recency of the War, the Securities and Exchange Commission's (the “SEC”) Division of Corporation Finance is yet to provide specific disclosure guidance related to the War. For context, when the geopolitical situation in Eastern Europe intensified in February 2022, with Russia's invasion of Ukraine, the Securities and Exchange Commission's (the “SEC”) Division of Corporation Finance released a sample letter reflecting comments it may issue to a registrant regarding compliance with the SEC's disclosure obligations. The sample letter underscores the need for registrants to evaluate both direct and indirect impacts of wars, including potential or actual disruptions to suppliers,

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