On July 15, the Department of State issued a statement concerning implementation of section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank). Section 1502 pertains to reporting requirements established for certain companies on whether they use certain minerals sourced from the eastern Democratic Republic of the Congo (DRC) that have helped to fund conflict in that region.
The statement said “that it is critical that companies begin now to perform meaningful due diligence with respect to conflict minerals. To this end, companies should begin immediately to structure their supply chain relationships in a responsible and productive manner to encourage legitimate, conflict-free trade, including conflict-free minerals sourced from the DRC and the Great Lakes region.” It also specifically endorsed the guidance that the Organization for Economic Cooperation and Development (OECD) had issued in May 2011 on responsible supply chains of minerals from conflict-affected and high-risk areas,” and encouraged companies “to draw upon this guidance as they establish their due diligence practices.”
This post was originally published on the legacy ABA Section of Administrative Law and Regulatory Practice Notice and Comment blog, which merged with the Yale Journal on Regulation Notice and Comment blog in 2015.