As a reminder, conflict minerals disclosures on Forms SD are required to be filed with the Securities and Exchange Commission (SEC) no later than May 31, 2019. There have not been any notable regulatory updates related to the conflict minerals rules since April 2017. At that time, the SEC’s Division of Corporation Finance issued blanket no-action relief, saying it would not recommend enforcement against companies for not complying with the requirement to conduct due diligence and file a “conflict minerals report,” although it would expect companies with conflict minerals in their supply chains to file a Form SD. (See our client alert “SEC Staff Provides Relief From Conflict Minerals Rule,” April 11, 2017.) Even though the no-action relief remains in effect, many companies have continued to conduct due diligence and file full conflict minerals reports with the SEC, given that they already have diligence processes in place and that some stakeholders have come to expect the reports.

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