In this article, Nate Lankford, Richard Mojica, and Quinnie Lin*, along with Stephenson Harwood lawyers Sue Millar and Jo Jones, discuss three key differences between the conflict minerals regulations passed by the EU and U.S. "Responsible companies with global operations in extractives, electronics, manufacturing and other sectors recognize that they operate in a complex and changing international landscape of legal and reputational risks associated with sourcing minerals. In particular, the new EU regulation is a reminder that the U.S. administration's potential suspension of the U.S. conflict minerals rules should not be considered in isolation, and that companies may be subject to multiple regulatory regimes in this area," the authors wrote. "To stay ahead of the curve in this context, companies that are currently subject to the U.S. rules should conduct a careful analysis to determine whether they may be covered by the EU regulations (i.e., whether they would qualify as a direct importer, smelter or refiner), and if so, consider ways to leverage existing compliance program components to comply with both regimes."

*Former Law Clerk