This week the U.S. Court of Appeals for the D.C. Circuit held that the Security and Exchange Commission’s (“SEC”) final rule concerning “conflict mineral” disclosures is unconstitutional. Nat’l Assoc. of Mfrs v. SEC, No. 13-5252 (D.C. Cir., decided April 14, 2014). The SEC rule requires registrants to disclose annually on a Form SD whether their … Continue Reading
What do the SEC and Leonardo DiCaprio have in common? Both have brought attention to the area of “conflict resources” in Africa. But whereas Leo has acted in a movie about so-called “blood diamonds,” the SEC is turning the spotlight on “conflict minerals.” Regrettably, the public will not be enjoying an SEC-produced summer blockbuster regarding … Continue Reading
Companies with global supply chains are rapidly imposing detailed standards for their suppliers that go way beyond the traditional performance and quality specifications. Until recently, the most obvious categories of concerns for global manufacturers were rules of origin for products and parts for purposes of customs valuations and treaties, heightened by protectionist legislation such as … Continue Reading
