Greenberg Traurig Forms Multi-disciplinary Legal Team to Help Companies Navigate New Compliance Requirements for Conflict Minerals

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Greenberg Traurig Forms Multi-disciplinary Legal Team to Help Companies Navigate New Compliance Requirements for Conflict Minerals

International law firm Greenberg Traurig, LLP announced the creation of a multi-disciplinary Conflict Minerals Compliance Initiative to help companies navigate the new reporting and compliance requirements for so-called “conflict minerals.” Relying on a mandate in the Dodd-Frank Wall Street Reform Act, the U.S. Securities and Exchange Commission (SEC) recently issued a rule requiring SEC-reporting companies to disclose the use of tantalum, tin, tungsten or gold originating in the Democratic Republic of the Congo or an adjoining country.

The new rule imposes a three-step compliance process for U.S. and non-U.S. SEC-reporting companies that manufacture (or contract to manufacture) products using any of the four conflict minerals and their derivatives. If conflict minerals are used in their products, and if those conflict minerals are sourced from the Democratic Republic of the Congo or an adjoining country, a company will be required to disclose that information and submit their due diligence process to a third-party audit. The rule does not apply to mining operations.

“While certain companies such as electronics manufacturers have been instituting procedures to address this new reporting requirement for some time, other businesses are just beginning to address it,” said Barbara A. Jones, shareholder in the Corporate and Securities practice and member of the Conflict Minerals Compliance Initiative. “The scope of the rules is broad, and companies will need to work with suppliers and others to prepare the necessary compliance reports.”

“Greenberg Traurig is able to leverage its global platform and more than 1700 attorneys to assist clients, and working as part of a multi-office, multi-practice team is our standard operating model,” said Donald Stein, shareholder in the Global Trade Practice and a member of the Initiative. “We are utilizing an integrated approach, tapping the knowledge of attorneys from the corporate and securities, global trade, consumer products, and natural resources/environmental practices to form compliance teams to advise our clients. We can assist SEC-registered clients facing these new reporting requirements, whether they are based in the U.S., Asia, Europe, the Middle East or elsewhere.”

“We have been analyzing the details and ambiguities of the rule and its application to various industries,” said Hamilton Hackney, environmental practice shareholder. “We are currently working with clients to help them apply the various definitions of the rules to their products and operations, develop and implement a compliance schedule and program, manage the disclosure process and address management of change issues in their operations going forward.”

Additional details related to the SEC’s final rules and Conflict Minerals reporting requirements are outlined in this Greenberg Traurig Alert: New-SEC-Rules-on-Conflict-Minerals-Pose-Significant-Challenges-for-Reporting-Companies, and information about Greenberg Traurig’s Conflict Minerals Compliance Initiative is available here: GT Conflict Minerals Compliance Initiative.

About Greenberg Traurig, LLP
Greenberg Traurig, LLP is an international, full-service law firm with approximately 1750 attorneys serving clients from 35 offices in the United States, Latin America, Europe, the Middle East and Asia. In the U.S., the firm has more offices than any other among the Top 10 on The National Law Journal's 2012 NLJ 250. For additional information, please visit

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Lourdes B. Martinez
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