Executive Order on Conflict Minerals? Not Yet

February 2017

As of midnight on February 14, 2017, no executive order relating to the SEC conflict minerals rule has been signed by President Trump. For an executive order not yet signed, it is getting a lot of attention, media coverage, even prompting webinars and law firm memos. All this attention has also created some confusion. So, while we wait for an executive order, let us review where we are.

Tucked away at the end of 2010’s Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) is a provision that required the SEC to issue a rule requiring SEC reporting companies to disclose certain information about the source and chain of custody of the conflict minerals (tin, tantalum, tungsten and gold) in their products.