With only 19 days left before the SECs Form SD filing deadline, there is still a lot of talk about consequences of the SECs April 7, 2017 Statement (“April 2017 Statement”). In that statement, the SEC staff indicated that it would not recommend enforcement action to the Commission if a company that is otherwise required to … Continue Reading
You may have read that President Trump signed an executive order repealing or waiving the SEC conflict minerals rule. Not true — at least not yet. As of February 14th, no executive order relating to the conflict minerals rule had been signed. But, a leaked draft of an executive order and rumors about a plan … Continue Reading
What Just Happened? April 7, 2016 was the deadline for filing a petition for writ of certiorari to the US Supreme Court seeking a review of the court of appeals’ decision on the conflict minerals rule. The SEC did not file the petition, and Amnesty International (the intervenor in the case) did not make the … Continue Reading
On September 2, 2015, a federal judge ordered the SEC to file, by October 2, 2015, an “expedited schedule” for issuing the final resource extraction payment rule (which was required by Section 1504 of Dodd-Frank). This order is added to an already complicated setting of: increased regulation from the US, states and other countries requiring … Continue Reading
May 17, 2013 – May 24, 2013 The summaries provided in this Weekly Recap do not necessarily represent the views of Squire Sanders (US) LLP and should not be deemed to be endorsements of them. The Recap is intended to be a compilation of articles and events to encourage discussion within the conflict minerals community and to keep … Continue Reading
The US House of Representatives has announced that this afternoon (Tuesday the 21st), the Financial Services Committee’s Subcommittee on Monetary Policy and Trade will hold a hearing on “The Unintended Consequences of Dodd-Frank’s Conflict Minerals Provision.” The hearing is scheduled for 2 p.m. Eastern time. The following witnesses are scheduled to testify: David Aronson, Freelance Writer, … Continue Reading
The article “Conflict Minerals Legislation: The SEC’s New Role as Diplomatic and Humanitarian Watchdog” scrutinizes the legislative history and lobbying efforts behind the conflict minerals provision and concludes that, unlike the majority of the Dodd-Frank bill, the conflict minerals rule goals are moral and political, rather than financial. The article argues that the presence of … Continue Reading