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Legal Update

Conflict Minerals: SEC Guidance and Appellate Court Decision

16 April 2014
Mayer Brown Legal Update

The Division of Corporation Finance of the US Securities and Exchange Commission has updated its frequently asked questions regarding its conflict minerals rule, providing guidance on nine conflict minerals topics. The new FAQs provide timely direction for public companies that need to file their first specialized disclosure reports on Form SD by June 2, 2014.

The US Court of Appeals for the District of Columbia Circuit has issued an opinion in the conflict minerals litigation brought by the National Association of Manufacturers, et al., holding that the conflict mineral statute and rule violate the First Amendment and remanding the case to the district court for further proceedings. Despite this, it is prudent for companies affected by the conflict minerals rule to continue their compliance efforts and to familiarize themselves with the recent FAQs until the district court or the SEC indicates otherwise.

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