The SEC recently adopted a rule which obligates any company that is registered under the Securities Exchange Act of 1934 to certify its use of "conflict free" minerals in its products.

The rule is complex, with a host of potential compliance, regulatory, policy and public affairs questions/opportunities. Original equipment manufacturers (OEMs) and large companies will be demanding that their chain of suppliers and every component manufacturer that uses tantalum, tin, tungsten, or gold, certify that their use and supply is "conflict free."