Recent Actions in the Conflict Minerals Provisions of the Dodd-Frank Act

In this article, Lamia Matta and Claire Palmer review ongoing litigation related to the SEC rules that implement the Dodd-Frank conflict-minerals provisions and analyze the recent court rulings. With the D.C. Circuit's final decision on the disclosure requirements of the SEC rules forthcoming, Matta and Palmer assess the impact the decision may have on the current due diligence requirements. The Court's ruling, they write, will affect the SEC requirement that companies declare in their public Form SD reports whether their products are or are not "conflict free." In the meantime, they conclude, companies "should monitor how the SEC views the thoroughness and quality of the reports that were submitted in June."
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