SEC's Conflict Minerals Rules: Strict, Onerous, Vague

Law360, New York (August 23, 2012, 1:47 PM EDT) -- The Conflict Minerals Rules mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act have ranked among the most controversial Dodd-Frank provisions — Aug. 22’s U.S. Securities and Exchange Commission open session announcement of the final rules helps explain why.

Whatever one’s position on the public policy wisdom of the announced final rules, it is now clear that auditing complex supply chains and vetting difficult-to-control vendors, often located worlds away, has become the new corporate imperative.

In the morning hours of Aug. 22, the commission...
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