February 1, 2017
We welcome reconsideration of the conflicts minerals rules. From our opinion as a firm that is active in Africa the consequence of these regulations, albeit they were well intentioned, has been to force activity into criminal areas which might otherwise have been undertaken legitimately.
There was no requirement for this issue to be addressed in the D-F Act. It was not a part of the financial crisis and its implementation has put an unnecessary burden on firms and certain fragile countries. With the extant FATF guidance being implemented throughout Africa and the knowledge of the regulations regarding financial crime general guidance regarding concerns supplementing the existing FATF regime would have been helpful rather than a blanket prohibition which only assists growth in criminal activity.