Funk Article on SEC Conflict Minerals Rules


In the morning hours of Aug. 22, law firms, boardrooms and compliance professionals around the globe were humming with anticipation (or perhaps more accurately, laboring under a chilly frisson of dread). The cause for this collective anxiety was the SEC’s much-anticipated – and much-delayed – announcement of the Dodd-Frank Act’s final disclosure and reporting rules concerning “conflict minerals.” This article, by Partner T. Markus Funk, examines the contours of the new rules from a retail perspective, and tries to answer the question of whether one man’s well-intentioned humanitarian effort has once again become another’s costly export of moral imperatives for difficult-to-achieve public policy objectives.