Conflict Mineral Rules Disclosure Requirements

News & Analysis as of

The Financial Choice Act: Implications for the U.S. Securities Legal Framework

On September 13, 2016, the House Financial Services Committee of the United States House of Representatives (the “FSC”) formally released H.R. 5983, the “Financial CHOICE Act” (the “CHOICE Act”). While the CHOICE Act has...more

SEC Rules for Resource Extraction Issuers Could Lead to Increased FCPA Scrutiny, Disclosures

New rules issued by the U.S. Securities and Exchange Commission (SEC) that require resource extraction issuers to disclose payments made to U.S. and foreign governments for the commercial development of oil, natural gas or...more

Preliminary Planning for the 2017 Proxy Season

For those who want to start preparing for the 2017 proxy season, our preliminary list of important considerations is set forth below: Directors’ and Officer’s Questionnaire - Nasdaq has adopted a rule requiring...more

New GAO Report Highlights Challenges in Complying with Conflicts Minerals Rule

Seyfarth Synopsis: Companies are experiencing difficulties in complying with their disclosure responsibilities under the SEC’s conflict mineral requirements. The Government Accountability Office (GAO) recently released a...more

How The Failure To Comply With The Conflict Minerals Law Can Expose Manufacturers To Criminal Penalties

Last year, we provided an overview regarding the requirement that U.S. publicly traded companies disclose their use of “conflict minerals.”  As of 2014, the Government Accounting Office reported that 1,321 companies filed the...more

SEC Adopts Resource Extraction Issuer Disclosure Rule – Changes From the Proposed Rule and Take-aways for Issuers

On June 27, the SEC adopted Rule 13q-1 under the Exchange Act and related amendments to Form SD. Under the Rule, public companies are required to annually report on payments made to foreign governments and the U.S. federal...more

Key Milestone towards the Standardisation of Mineral Reserve and Resource Reporting

The US Securities and Exchange Commission (the "SEC") has proposed to modernise its rules for mineral property disclosure and more closely align them with international regulatory standards and practices. The SEC has...more

SEC Proposes Updated Mining Disclosure Rules ? Industry Guide 7 to be Eliminated

On June 16, 2016, the SEC proposed new rules to update disclosure requirements for mining properties. The intent of the proposed rules is align them more closely with current industry and global standards, specifically...more

"Conflict Minerals Disclosures Due May 31, 2016"

Companies that are required to make conflict minerals disclosures on Form SD with the U.S. Securities and Exchange Commission (SEC) for calendar year 2015 must do so no later than Tuesday, May 31, 2016....more

AG Explains Why the Conflict Minerals Decision Was Not Appealed to the Supreme Court

Loretta Lynch, United States Attorney General, explained in a letter to Paul Ryan, Speaker of the House, why the United States did not submit a writ of certiorari with respect to the conflict minerals decision: - The...more

Apple’s Conflict Minerals Smelters Nearly 100% Audited

Apple has filed its Form SD for the year ended December 31, 2015. It includes this disclosure: The combination of training, public reporting and a ticking clock drove the number from 82 smelters and refiners...more

In Case You Missed It - Interesting Items for Corporate Counsel - March 2016

For those gearing up for the 2015 conflict minerals report, due June 1, 2016, note that nothing on the legal front has changed. The D.C. Circuit Court’s ruling that requiring a company to state whether its products are “DRC...more

Supply chain management and the conflict minerals rules – action items for 2016

In enacting Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, Congress expressly stated its view that “the exploitation and trade of conflict minerals is helping to finance conflict characterized...more

"Planning for the 2016 Annual Meeting and Reporting Season"

Each company faces important decisions in preparing for its 2016 annual meeting and reporting season. We have prepared a checklist of essential areas we believe companies should focus on as they plan for 2016, including...more

D.C. Court of Appeals Denies Request for Rehearing on Conflict Minerals Rules

On November 9, 2015, the U.S. Court of Appeals for the District of Columbia Circuit denied petitions filed by the Securities and Exchange Commission (SEC) and Amnesty International requesting a full panel rehearing of its...more

Blog: D.C. Circuit Denies SEC’s Petition For Rehearing En Banc In Conflict Minerals Case

Hot off the press: The D.C. Circuit today issued a per curiam order denying the petitions of the SEC and Amnesty International for a rehearing en banc in Natl Assoc. of Manufacturers v. SEC, the conflict minerals case. No...more

Managing Legal and Reputational Risks in an Era of Enhanced Transparency

Companies face a range of new requirements and expectations calling for enhanced transparency regarding human rights-related risks in connection with their operations. Responsible compliance with both mandatory requirements...more

Blog: U.S. Chamber Of Commerce Won’t Challenge Pay-Ratio Rules — At Least For Now — And Will Focus Instead On Conflict Minerals...

The WSJ is reporting that, contrary to all expectations (including my own), “the U.S. Chamber of Commerce isn’t planning to mount a legal challenge to the Securities and Exchange Commission’s pay ratio rule.”...more

Blog: Is A Lot More At Stake In The Conflict Minerals Case Than The Conflict Minerals Disclosure Rules?

An amicus brief filed in the conflict minerals case, National Association of Manufacturers, Inc. v. SEC, was submitted this week by a group of anti-smoking and other organizations dedicated to protecting public health: Truth...more

SEC’s Conflict Minerals Rule Still Unconstitutional, Says D.C. Circuit

On August 18, 2015, the United States Court of Appeals for the District of Columbia Circuit reaffirmed that both Section 1502 of the Dodd-Frank Act and its implementing Conflict Minerals Rule issued by the SEC violate the...more

Blog: SEC To Issue Final Dodd-Frank Resource Extraction Disclosure Rule By June 2016 (Maybe)

As noted in this Law 360 article and in this thecorporatecounsel.net blog , on Friday, the SEC filed a Notice of Proposed Rulemaking in the U.S. District Court for the District of Massachusetts in connection with Oxfam...more

Blog: No Surprise Here: SEC And Amnesty File Petitions For En Banc Rehearing In The Conflict Minerals Case

To no one’s surprise, on Friday, the SEC and Amnesty International filed petitions for en banc rehearing in the conflict minerals case, National Association of Manufacturers, Inc. v. SEC. That case, decided two-to-one in...more

Preliminary Planning for the 2016 Proxy Season

Some will want to start preliminary planning for the 2016 proxy season. It has been a bewildering year of developments, but most will be thankful that there are relatively few new rules that must be implemented at this time....more

Blog: District Court Compels SEC To Provide “Expedited Schedule” For Issuing Dodd-Frank Resource Extraction Rule — Will Other Rule...

A U.S. District Court has handed a victory to Oxfam America in its efforts to compel the SEC to complete rulemaking on the Dodd-Frank mandate regarding resource extraction disclosures (Section 1504). ...more

D.C. Circuit Court Re-Affirms Decision that Portions of SEC’s Conflict Minerals Rules are Unconstitutional

On August 18, 2015, the United States Court of Appeals for the D.C. Circuit, in likely the first majority opinion citing Charles Dickens (A Tale of Two Cities) and George Orwell (Nineteen Eighty-Four), re-affirmed its...more

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