In early September, the US Department of Commerce published what it called “the most comprehensive list to date of all known [conflict minerals] processing facilities in the world.”
Well, they were close. It is indeed a list of conflict minerals processing facilities around the globe.
Not only was Commerce unable to determine which of these processes ores that fund or benefit armed groups, but we are now hearing the list itself contains errors and omissions.
So what does this mean? It means this is yet another list that issuers and their suppliers will need to conduct their own due diligence on, rather than relying on it wholly. Last year, several companies that simply relied on a spreadsheet list of processing facilities ended up erroneously disclosing that one source of their gold was the Central Bank of North Korea.
To assist companies facing the potentially significant effort of checking on all smelters/refiners identified by their suppliers, we recently announced a new service focused on those activities.