GAO Says Commerce Department Has Not Complied With Conflict Minerals Obligations

The Government Accountability Office, or GAO, has issued a report noting the SEC  issued a rule in 2012 requiring certain companies to disclose the source and chain of custody of necessary conflict minerals in their products.  However, the report notes the Department of Commerce has not yet compiled a list of all conflict minerals processing facilities—smelters and refiners—known worldwide, required by January 2013 pursuant to the Dodd-Frank Act. Commerce cited difficulties with, for example, tracking conflict minerals operations but told GAO that it had completed outreach efforts with the majority of stakeholders. According to GAO Commerce did not have a plan of action, with associated time frames, for developing and reporting on the list of conflict minerals processing facilities worldwide. The GAO said standard practices in program and project management include, among other things, developing a plan to execute specific projects needed to obtain defined results within a specific time frame. The GAO thinks an action plan with timeframes could better position Commerce to report on the status of its efforts to produce a final list to Congress and to hold its personnel accountable for completing activities.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Stinson Leonard Street - Dodd-Frank and the Jobs Act | Attorney Advertising

Written by:


Stinson Leonard Street - Dodd-Frank and the Jobs Act on:

Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.