This publication discusses the conflict minerals rules passed in individual states prior to the federal legislation. Topic on conflict-free initiative. Lessons learned from conflict diamonds. SEC moves to enhance analysis of economic impact of regulations.
Compliance with the provision will be a daunting task—many businesses will find it difficult to conduct due diligence on the origin of the conflict minerals. Considering the current ambiguity around the provision, the major hurdle for businesses will be to devise a strategy to determine the source of materials.