On May 28, 2020, Flex Ltd (Flex), a Singapore-based electronics manufacturer listed on the NASDAQ, disclosed in its 2020 US Securities and Exchange Commission (SEC) filing that it had initiated a voluntary self-disclosure to the US Office of Foreign Assets Control (OFAC) on February 14, 2019. The initial disclosure related to possible non-compliance with US sanctions by certain non-US companies affiliated with Flex. According to the SEC filing, an internal investigation is ongoing and Flex expects to complete the investigation and final disclosure to OFAC by the end of its second quarter of its fiscal year 2021.
We set out in our recent blog post some key messages, which may help you navigate complex issues of sanctions law.
Dealing with distress: business restructuring and rescue
Businesses in every sector and geography are having to transition to new ways of operating within a rapidly changing and increasingly uncertain legal and regulatory landscape.