In the following guest post, Evan Bundschuh and Burkhard Fassbach share and analyze their research into the geopolitics-related Form 10-K disclosures of 26 large-cap U.S.-listed public companies, as well as 52 small-cap and mid-cap companies, in order to assess the level and significance of public companies’ disclosure statements pertaining to geopolitics. Evan is Vice President at GB&A, a retail insurance brokerage in New York, and Burkhard is a D&O lawyer in private practice in Germany. My thanks to Evan and Burkhard for allowing us to publish their article on this site. Here is their article.
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As previously discussed in our prior post, risks related to artificial intelligence are a leading concern among corporate officers, fueling more disclosures and greater transparency in 10k filings. For many companies however, geopolitical risks are an even greater concern – risks that have quickly escalated beginning with Covid’s imposed shutdowns and resulting shipping delays, to constantly shifting tariffs, sanctions, and supply chain risks posed by ongoing armed conflicts. As a result, geo-political disclosures within 10K filings have evolved considerably. Where prior disclosures were more blanketed boilerplate statements acting as catch-alls, the geo-political disclosures that are emerging have become considerably more abundant and specific in nature. The evolution of these disclosures goes hand in hand with recent guidance issued by major law firms advising that public companies (particularly those with international supply chains, substantial import or export exposure, or global sourcing) assess whether tariffs, trade restrictions, or trade policy changes could materially affect their business or results of operations.
To assess the frequency and specificity of the disclosures themselves, we sourced the filings of 26 companies across a variety of sectors in the large cap range – as listed in the Reference Appendix. In addition, we analyzed 52 small cap and mid cap companies. Our study yielded some interesting findings, with considerable variation across sectors and market caps.
Roughly 90% of large cap companies in our sample group referenced specific geopolitical risks within their disclosures. Had the sample omitted US healthcare companies (who lacked meaningful disclosures) that number would have been close to 100%. This is in contrast to approximately 73% of mid cap companies and approximately 50% of the small cap companies who noted such risks within their filings. There was also considerable variation among sectors. Whereas all of the small cap tech, automotive, energy and chemical companies did disclose specific risks, smaller cap companies operating in the consumer products, healthcare, insurance, and finance/banking sectors often lacked any disclosures. It should be noted that these companies were often those with limited foreign risk such as smaller consumer product brands, community banks and domestic insurers. Despite reduced foreign exposures however, such companies may in fact still be exposed to geopolitical risk. Potential cyber-attacks by nation state actors, retaliatory boycotts, and effects of future pandemics (risks cited by some of the larger cap companies) are just a few such examples. The analysis also reveals some thematic clusters:
1. Tariffs and Inflation
Unsurprisingly, among the themes identified in 2025 filings, disclosures related to tariffs were the most prominent, as companies are no longer treating tariff risk as a theoretical future concern but are now acknowledging their wider implications.
At their most basic, a number of companies have cited tariffs and high inflation as creating procurement challenges (including hardware for internal usage) that could affect supply chains‘ timing and profit margins. Consumer goods companies such as Coca-Cola, PepsiCo, and McDonald’s are being particularly affected by the impact of trade measures on agricultural commodities and retaliation in markets where US tariffs have generated political backlash – demonstrating the emergence of reputational risk as a result of geo-political tensions. Interestingly, at least one consumer products company even cited „impacts on consumer confidence and expectations around inflation and currencies“ as a cause of (negative) consumption trends. Disclosure of potential exposure to anti-corruption laws and potential risk of expropriation was also noted among the filings.
The automotive sector is another great example of how such disclosures are evolving. In addition to disclosing reduced market demand and procurement challenges, some of the large auto manufacturers are also disclosing their strategic responses under consideration, including domestic reshoring initiatives, supplier renegotiations, and pricing adjustments, demonstrating that investors‘ expectations have evolved from merely acknowledging known risks, to actively managing them.
2. Export Controls, Trade Policy, Sanctions and Forced Exit Risk
Technology companies are among those facing the most pressure. The expansion of U.S. Bureau of Industry and Security (BIS) export controls to cover advanced AI training chips (including certain GPU configurations and AI accelerator hardware) has created a direct link between AI strategy and geopolitical risk disclosure. Despite the fact that one of the large tech companies in our cohort doesn‘t provide any consumer-facing services in China, the company still disclosed geopolitical risk related to U.S.–China tensions, including the „risk that escalating trade measures could produce retaliatory restrictions on U.S. digital services companies globally, or that legislative action in the U.S. could restrict the company’s ability to operate in specific jurisdictions“. Similarly, another large tech company’s disclosures cites, „such restrictions could impair its ability to deploy AI infrastructure globally, limit cloud service offerings in certain jurisdictions, or constrain the operation of data center facilities using controlled hardware“. In addition to the potential for retaliatory restrictions, tech companies are also being affected by escalating restrictions on US investments in Chinese technology (and vice versa).
Chemical companies, operating in a particularly volatile regulatory environment, contained some of the more complex disclosures. Many addressing procurement challenges arising from export controls from China, EU compliance exposure related to climate and carbon regulations such as CBAM (the Carbon Border Adjustment Mechanism), and constantly shifting end-Use certificate requirements.
Government mandated supply chain audits and domestic sourcing requirements (emerging from both US and EU regulations) are also creating the potential for supply chain shortages of generic active pharmaceutical ingredients (APIs), resulting in a number of large pharmaceutical companies routinely disclosing risks associated with their active ingredient procurement supply chains – a substantial portion of which runs through Chinese manufacturers. Another notable disclosure made by companies operating in the Chemical sector, was the ingredients potential for U.S.–China trade tensions to create regulatory “whipsawing”; the simultaneous application of conflicting national rules to the same global supply chain.
One of the lesser recognized risks, is the resulting shift in competition. According to one large pharmaceutical company, „In China, we expect to continue to face intense competition by certain generic manufacturers, which has resulted, and may result in the future, in price cuts and volume loss of some of our products.“ Logistics-separation challenges are also emerging. Per the disclosures made by a separate pharmaceutical company, “Finding alternative suppliers if and as necessary due to geopolitical developments or otherwise may not be feasible or could require significant time and expense due to the nature of our products and the need to obtain regulatory approvals”.
Many of the large energy companies disclosed China-related geopolitical risk primarily in the context of liquefied natural gas (LNG) off-take agreements and downstream petrochemical joint ventures. Disclosures in this sector have evolved from more generic „international operations risk“ to now specifically addressing the risk of contract disruption or counterparty non-performance in response to any potential increased tensions between the U.S. and China.
Companies operating in the banking sector provided some of the most detailed disclosures within the analysis. All four institutions disclosed risks associated with the expansion of U.S. and allied country sanctions targeting Russian, Iranian, and other designated entities. Of particular note are disclosures concerning secondary sanctions risk; the potential exposure arising not from direct dealings with sanctioned parties, but from transactions with third parties who may themselves have sanctioned counterparty relationships. The following disclosure made by one large US bank effectively summarizes such risk, „The Firm is also subject to the regulations and economic sanctions programs administered and enforced by the U.S. Treasury’s Office of Foreign Assets Control (“OFAC”) and EU and U.K. authorities which target entities or individuals that are, or are located in countries that are, involved in activities including terrorism, hostilities, embezzlement or human rights violations.“ The resulting secondary-sanctions poses a number of challenges, as it is difficult to quantify and nearly impossible to fully eliminate, making it one of the most challenging geopolitical risk categories for both disclosure and D&O insurance purposes.
3. ESG Tensions
Some companies are also encountering compliance challenges.The filings frommajor pharmaceutical leaders now explicitly address the friction between public ESG pledges and sourcing dependencies in high-risk regions. A primary example is the Uyghur Forced Labor Prevention Act (UFLPA). Companies disclose that government-mandated supply chain audits are often at odds with the limited transparency permitted by local authorities in key manufacturing hubs, creating a “transparency vacuum”.
Similar to the risks posed by AI-washing, companies many also become the target of inaccuracies related to their ESG commitments. From a D&O perspective, this section of the 10-K has evolved from target setting, to more of a defense mechanism against ESG-washing liability. If a company maintains high-profile sustainability ratings or public human rights commitments but fails to disclose the geopolitical obstacles to achieving them, it faces potential securities litigation when they are ultimately unable to live up to their commitments.
The 2025 filings also document a new risk: Divergent stakeholder pressure and”anti-ESG” backlash. According to the filings of one large consumer products‘ company, “There also exists ‘anti-ESG’ sentiment among certain stakeholders and government entities, which may result in scrutiny, reputational risk, product boycotts, lawsuits or market access restrictions… regarding our sustainability policies”. This risk is echoed again in disclosures made by one of the company’s competitors stating, „We could also be subjected to negative responses by governmental actors (such as anti-ESG legislation or retaliatory legislative treatment) or certain stakeholders (such as boycotts, litigation or negative publicity campaigns) that could adversely affect our business.“. Together these disclosures are evidence that meeting ESG targets and international sustainability standards can trigger retaliatory legislative action or boycotts in domestic or foreign markets. This leaves directors in a “whipsaw” position, where compliance with one jurisdiction’s ESG disclosure rules (like the EU’s CSRD) may create reputational or regulatory friction in another.
As a result, some companies have also disclosed amendments to their carbon targets. One large energy provider disclosing, „(our company) has set a number of lower carbon-related ambitions, which may include aspirations, targets, guidance, objectives, metrics, and/or goals…The company has changed and/or eliminated some of these aspirations, targets, and other ambitions and may continue to do so in the future for various reasons, including market conditions; its strategy or portfolio; and financial, operational, policy, reputational, legal and other factors.“
For boards, the 2025 filings signal that ESG related risk has evolved from simply demonstrating social responsibility and meeting targets, to recognizing the logistical challenges and carefully balancing ESG efforts against any potential financial, reputational and litigation risks.
4. Armed Conflicts, Terroristic Attacks, Civil Unrest and Retaliatory Cyber Attacks
Ongoing conflicts were another large driver of geo-political disclosures. These disclosures tended to fall into a few categories.
Many companies in the consumer products, energy, automotive and technology sectors regularly cited risks associated with; the conflicts in Ukraine and the middle east, recent attacks in the Red Sea, China’s threats to annex Taiwan, political conflicts near the Suez Canal, and potential terrorist attacks. These disclosures increased in frequency and specificity for companies that maintained greater foreign operations in affected countries. Among the disclosures observed were: supply chain and procurement challenges, increased cost of energy and agricultural commodities, potential for bans or boycotts, and potential for sabotage, as a result of the conflicts.
Companies in the hospitality and travel sectors are being particularly affected, routinely disclosing the potential for decreased revenue as a result of decreased travel demand, heightened travel security measures, and economic conditions in affected countries.
Several companies in the consumer products and telecom sectors also disclosed their suspension of exports to certain countries involved in current conflicts. These disclosures demonstrate that reputational risk is not limited to retaliation in response to the imposition of tariffs but extends to current and ongoing armed conflicts. Some Financial institutions and energy companies also cited potential credit risk from sovereign debt holders, difficulties in predicting future commodity pricing, and the effects geo-political tensions could have on global financial and energy markets.
Companies operating in the insurance sector are also facing multi-faceted challenges. In addition to the operational risks posed to their own investment portfolios, geo-political tensions are also creating underwriting challenges (through underwriting war risk, political risk policies, and sovereign credit instruments) – with many carriers reassessing their war risk exclusions.
Another risk often cited by companies with larger market caps, and more common among tech companies and financial institutions, was the potential for cyber warfare, retaliatory cyber-attacks, and potential for civil unrest. The following disclosure from a large US bank evidences the risks being addressed in recent filings, „(our company) continues to operate in multiple jurisdictions in the midst of geopolitical unrest or uncertainties, including, among others, those affected by the Russia–Ukraine war and the conflicts in the Middle East, which could expose (us) to heightened risk of insider threat, cyber threats from nation-state actors, hacktivists or other cyber incidents.“
While some companies further went on to disclose the potential risk of attacks on infrastructure and/or infrastructure failures, energy companies are undoubtedly encountering the greatest risk, as evidenced by one large energy provider in our cohort who issued disclosures pertaining to recent drone attacks that could affect their oil fields. While not fully reflected in these most recent filings, the tensions with Iran and the Strait of Hormuz will only add more complexity to future disclosures in the energy sector.
5. Future Pandemics, Viruses and Government Response
A final theme not formally discussed in the above, that we’ll touch upon briefly, were disclosures related to future pandemics, outbreaks and any government responses. Such disclosures were identified within filings across all sectors. Many filings routinely cited potential supply chain and business interruptions, staffing shortages and even changes in consumer behaviors, expectations and competition. Government response risks, including potential business shutdowns, shelter in place orders, and reduced travel was also regularly cited, particularly among hospitality companies. Lastly, a handful of companies specifically referenced the potential for increased litigation (as evidenced by Covid-19), and the potential for market turmoil to illicit stock drops, while also creating challenges accessing capital on favorable terms.
Conclusion
The 2025 10-K filings demonstrate that geopolitical risk management has evolved from a peripheral operational concern into a core governance obligation. Our analysis shows that corporate disclosures have moved decisively away from blanket, boilerplate language toward granular, sector-specific risk mapping. International volatility now permeates every facet of corporate strategy, and disclosure practices have adapted accordingly.
This shift toward micro-level disclosure carries significant legal and fiduciary implications for directors and corporate officers. The unprecedented specificity found across the 26 large-cap and 52 small- and mid-cap filings analyzed suggests that general awareness of geopolitical risk is no longer a sufficient defense against regulatory scrutiny or shareholder dissatisfaction. As companies increasingly document detailed operational vulnerabilities, boards are correspondingly held to a higher standard of accountability—what was once disclosed in general terms now sets a documented benchmark against which board oversight can be measured.
The 2025 filing season should therefore serve as a wake-up call for corporate boards. To mitigate the rising tide of event-driven Directors and Officers (D&O) liability claims and securities litigation, boards must move from passive risk acknowledgment to active, real-time oversight. Implementing robust, technologically advanced systems to monitor shifting tariffs, trade policies, and global friction points is no longer optional; it is a baseline requirement for safeguarding corporate resilience, preserving investor confidence, and ensuring long-term stability in an increasingly fragmented global market.
The following 26 unique companies provided the foundational data for this analysis through their Form 10-K filings for the fiscal year ended December 31, 2025.
Technology
Automotive
- Ford Motor Company
- General Motors Company
- Tesla, Inc. (Also listed under Technology)
Banking
Insurance
Healthcare / Health Insurance
Pharmaceutical
Food & Beverage
Telecommunications
Energy / Oil & Gas
Chemical