Conflict Minerals Reporting Requirements
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The New SEC Conflict Minerals Rule: Overcoming the Challenges of Compliance
On January 1, 2021, the Conflict Minerals Regulation (EU Regulation 2017/821) came into full force across the EU. This new law aims to ensure that importers of certain materials originating from conflict-affected and...more
On April 7, 2017, the Securities and Exchange Commission ("SEC") Division of Corporate Finance (the "Division") indicated that it will not recommend enforcement of the conflict minerals source and chain of custody due...more
The GAO has recently issued its third annual report on conflict minerals. The GAO is required by Dodd-Frank to report annually on the effectiveness of the SEC’s conflict minerals rule in promoting peace and security in the...more
GAO released an analysis of a generalizable sample of conflict minerals disclosures filed with SEC in 2015. The analysis found that an estimated 49 percent of companies in 2015 reported having determined whether the conflict...more
On April 5, just prior to the release of Corp Fin’s Updated Statement on conflict minerals, the Senate Subcommittee on Africa and Global Health Policy held a hearing on the effects on the Democratic Republic of the Congo of...more
The Securities and Exchange Commission (SEC or Commission) Division of Corporate Finance issued a new statement adding some uncertainty to company obligations and enforcement exposure under the SEC conflict minerals rule...more
Bloomberg BNA is reporting that the State Department has launched a new review of “how best to support responsible sourcing of conflict minerals,” which will continue through April 28. Although it’s not known whether the SEC...more
The GAO has issued its annual conflict minerals report to Congress, entitled “Companies Face Continuing Challenges in Determining Whether Their Conflict Minerals Benefit Armed Groups.” The GAO is required to report annually...more
Just in time for those Forms SD and conflict minerals reports, due May 31, the OECD has posted a new edition of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk...more
The SEC largely prevailed in the D.C. Circuit Court of Appeals in a suit changing the Rules promulgated by the agency under Dodd-Frank regarding conflict minerals. National Association of Manufacturers v. SEC, No.. 13-5252...more
A federal district court in Washington, D.C. has rejected an industry challenge to the Securities and Exchange Commission’s conflict minerals rules (the “Rules”) issued pursuant to Section 1502 of the Dodd-Frank Act....more
The European Commission (EC) Directorate-General for Trade has issued a consultation to solicit interested parties’ views on a potential EU initiative for responsible sourcing of minerals coming from conflict-affected and...more
Introduction - On August 22, 2012, the U.S. Securities and Exchange Commission (the “SEC”) adopted new rules (the “Final Rules”) pursuant to Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act...more
On December 4 and 5, more than 1,000 participants from 85 countries gathered for the first U.N. Forum on Business and Human Rights in Geneva, Switzerland. The Forum focused on “trends and challenges” in the implementation of...more
On August 22, the Securities and Exchange Commission (SEC) adopted a controversial and far-reaching rule laying out the obligations that publicly traded companies must meet under the "Conflict Minerals" provisions of the...more