March 21, 2014 – March 28, 2014
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 our readers updated on the most recent developments.
AICPA Provides Conflict Minerals Audit Guidance
According to its press release, the AICPA recently released new nonauthoritative guidance that includes three (3) examples of the independent private sector audit report. The guidance also addresses how a practitioner would communicate findings that are required to be communicated by Generally Accepted Government Auditing Standards and whether the practitioner may report either directly on the subject matter or on management’s assertion for each of the two audit objectives.
As the initial calendar year reporting deadline draws nearer, we expect to see similar guidance from other trade associations regarding Form SD, Conflict Minerals Reports and Independent Private Sector Audit reports.
The Washington Post Doubts That the Conflict Minerals Rule Was the Demise of the M23 Rebel Movement
At the end of last year, various news outlets reported that the M23 rebel movement in the eastern Democratic Republic of the Congo (DRC) had collapsed. Recently, John Prendergast, c0-founder of Enough Project, claimed that one of the reasons behind the downfall of the M23 rebel movement was the conflict minerals rule. Mr. Prendergast hinted that the rebel movement was in part funded by the trade of conflict minerals and since the adoption of the conflict minerals rule in August 2012, many companies reformed their supply chains to prevent the financing of armed conflict in the DRC.
Laura Seay, an Assistant Professor of Government at Colby College and contributor to the Washington Post, disagrees with Mr. Prendergast’s claim. Ms. Seay states, among other things, that the M23 rebels never controlled the mining areas in the DRC.
This debate will be worth paying attention to in the coming years. If policy makes believe that the conflict minerals rule is successful in reducing armed conflict, one could expect calls for additional regulations in the future.