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SEC’s Disclosure Requirement on Conflict Minerals Again Ruled Unconstitutional — What Now?

In a long-awaited decision, a three-judge panel of the U.S. Court of Appeals for the District of Columbia Circuit (DC Circuit) reaffirmed its prior decision, striking down one aspect of the SEC’s conflict minerals disclosure...more

Gaps in New DOD Counterfeit Parts Rules Raise Compliance Questions for Contractors

The U.S. Department of Defense (DOD) published, on May 6, 2014, its first set of final regulations imposing specific obligations on defense contractors and their suppliers for the detection and avoidance of counterfeit...more

What’s Next for Conflict Minerals Rules After D.C. Circuit Decision?

On April 14, 2014, the U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit) issued its long-anticipated ruling in the industry challenge to the Securities and Exchange Commission’s (SEC) conflict minerals...more

D.C. Circuit Partially Strikes Down SEC Conflict Minerals Rules

On April 14, 2014, the U.S. Court of Appeals for the D.C. Circuit issued its long-awaited decision in the challenge to the SEC’s conflict minerals disclosure rule filed by the National Association of Manufacturers (“NAM”) and...more

Could “Free Speech” Issues Derail the SEC’s Conflict Minerals Rule?

Shortly after the Securities and Exchange Commission (“SEC”) adopted its conflict minerals disclosure rule in August 2012, a coalition of business interests filed suit to challenge the SEC’s rule as unduly burdensome. That...more

Judges Sharply Question SEC On Conflict Minerals Rule

Shortly after the Securities and Exchange Commission (“SEC”) adopted its conflict minerals disclosure rule in August 2012, a coalition of business interests filed suit to challenge the SEC’s rule as unduly burdensome. That...more

DOD's Proposed Counterfeit Parts Regulations for Contractors Provide Some Answers, But More Questions

Coming not long after the issuance of its new internal policy guidance on counterfeit materiel, the U.S. Department of Defense (DOD) published on May 16, 2013 its first set of proposed regulations that would impose specific...more

New DOD Internal Policy Guidance on Counterfeit Parts: A Preview of Contractor Regulations?

The Department of Defense (DOD) has issued a new instruction that establishes internal DOD policies for detecting, avoiding, and remediating counterfeit parts in the DOD supply chain, and allocates responsibility among...more

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