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Robinson+Cole Manufacturing Law Blog

The End of Conflict Minerals?

We have been talking about conflict minerals for years.  And, so have our manufacturing clients.  As covered previously in this blog, the conflict minerals laws and regulations are some of the most well known, but least...more

Dorsey & Whitney LLP

SEC Enforcement after Kokesh and Cohen

Dorsey & Whitney LLP on

The remedies the Securities and Exchange Commission (“SEC”) can seek in its enforcement actions are a critical question in the wake of the Kokesh v. SEC, 137 S.Ct. 1635 (2017) and SEC v. Cohen, Civil Action No. 17-cv-430...more

Stinson - Corporate & Securities Law Blog

SEC Staff Relaxes Conflict Minerals Reporting

Effective immediately, the SEC staff has relaxed conflict minerals reporting requirements by public companies. The change was triggered by the entry of a final judgment in the conflict minerals case. ...more

Snell & Wilmer

Corporate Communicator - Spring 2017 - Recent Developments Regarding the Conflict Minerals Reporting Requirements

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On January 31, 2017, Michael Piwowar, Acting Chairman of the Securities and Exchange Commission (the “SEC”), issued two Statements regarding the current status of guidance on and implementation of the conflict minerals rules....more

The Volkov Law Group

SEC Snares Two “Masterminds” Behind Och-Ziff Bribery Scheme

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The SEC recently filed a lengthy civil complaint against two Och-Ziff executives: Michael Cohen, who headed Och-Ziff’s European office, and Vanja Barros, an executive responsible for Africa-related transactions, charging them...more

Stinson - Corporate & Securities Law Blog

SEC Reconsidering Conflict Minerals Implementation

SEC Acting Chairman Michael S. Piwowar issued a “Statement on the Commission’s Conflict Minerals Rule” and another statement titled “Reconsideration of Conflict Minerals Rule Implementation.” Chairman Piwowar reviewed...more

King & Spalding

Tokyo Dispute Resolution & Crisis Management Newsletter – December 2016

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Major FCPA Enforcement Action - Including charges against the CEO and CFO for failing to prevent misconduct - In one of the largest FCPA settlements in history, hedge fund Och-Ziff Capital Management Group LLC...more

The Volkov Law Group

FCPA Enforcement Ramping Up Against Private Equity and Hedge Funds (Part III)

The Volkov Law Group on

The Och-Ziff settlement has now set the stage for the Justice Department and the SEC to focus its enforcement eye on the private equity and hedge fund industry. The Och-Ziff action was initiated in response to the SEC’s...more

King & Spalding

Major FCPA Enforcement Action Against Nation’s Largest Publicly Traded Hedge Fund

King & Spalding on

In one of the largest FCPA settlements in history, hedge fund Och-Ziff Capital Management Group LLC (“Och-Ziff”) recently resolved a long-running government inquiry by agreeing to $413 million in financial penalties and a...more

The Volkov Law Group

DOJ and SEC Deliver Body Blow to Private Equity and Hedge Funds: Och-Ziff Settles FCPA Violations for $412 Million (Part I)

The Volkov Law Group on

The Justice Department and the Securities Exchange Commission delivered a powerful FCPA enforcement message to private equity and hedge funds. Och-Ziff settled with the DOJ and SEC for total penalties of $412 million....more

Seyfarth Shaw LLP

New GAO Report Highlights Challenges in Complying with Conflicts Minerals Rule

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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

Stinson - Corporate & Securities Law Blog

GAO Says Companies Face Continuing Challenges in Determining Whether Their Conflict Minerals Benefit Armed Groups

GAO noted in a recent report that as a result of country-of-origin inquiries, an estimated 19 percent more companies that filed Form SD with the SEC reported that they knew or had reason to believe they knew the source of the...more

Alston & Bird

D.C. Circuit Reaffirms 2014 Opinion on Conflict Minerals Rule

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On August 18, 2015, the U.S. Court of Appeals for the D.C. Circuit reaffirmed its 2014 ruling that struck down the requirement that public companies must disclose to the Securities and Exchange Commission (SEC), and on their...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Conflict Minerals Disclosure Requirement Confirmed Unconstitutional"

On August 18, 2015, the U.S. Court of Appeals for the District of Columbia Circuit, in a 2-1 decision (opinion available here), confirmed its earlier decision in April 2014 by ruling that the U.S. Securities and Exchange...more

Mintz - Securities & Capital Markets...

DC Circuit Court Reaffirms Earlier Decision Partially Invalidating Conflict Minerals Rule On First Amendment Grounds

Pursuant to Section 1502 of the Dodd-Frank Act, which added new Section 13(p)(1) to the Securities Exchange Act of 1934, as amended, the SEC promulgated Rule 13p-1 (the “Conflict Minerals Rule”), which required that issuers...more

Beveridge & Diamond PC

D.C. Circuit Reaffirms Previous Conflict Minerals Decision: Disclosure Requirement Violates First Amendment

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In a 2-1 decision, a three-judge panel from the U.S. Court of Appeals for the D.C. Circuit reaffirmed its previous decision striking down a narrow portion of the U.S. Securities and Exchange Commission’s (“SEC”) conflict...more

Cooley LLP

Blog: New GAO Report On Conflict Minerals Compliance

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By coincidence, the same day that the three-judge panel of the D.C. Circuit struck down (again) a portion of the conflict minerals rule (see this post), the GAO issued a report to Congressional Committees entitled “SEC...more

Faegre Drinker Biddle & Reath LLP

D.C. Circuit Reaffirms That Portions of Dodd-Frank Conflict Minerals Rules Violate First Amendment

On August 18, 2015, the United States Court of Appeals for the District of Columbia Circuit reaffirmed its ruling in National Association of Manufacturers v. Securities and Exchange Commission that portions of the SEC’s...more

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