Six degrees of separation? For conflict minerals requirements, Congo may be closer than you think

Being able to demonstrate a tangible tone-at-the top is a good place to start building a potential defense to an enforcement action

U.S. economic sanctions, for years relatively stable in their targeting of the “usual suspects,” state sponsors of terrorism and shadowy drug traffickers have gone into overdrive of late. Since the year began, the Obama administration handed out multibillion dollar fines against European banking giants and layered on complex new prohibitions on dealings with companies in Russia and Ukraine, jihadis in Pakistan, Iraq and Syria, and Venezuelan government leaders. All this comes as talks that could see sanctions on Iran lifted or at least lessened are moving ahead.

Given all this activity, one might be excused for missing the fact that the Treasury Department’s Office of Foreign Asset Control (OFAC) has broadened the sanctions net cast at companies doing business with the Democratic Republic of Congo (DRC). Excused, that is, unless one were a U.S. company required to file annual reports with the Securities and Exchange Commission (SEC).

Contributing Author

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Greg Esslinger

Greg Esslinger is Senior Managing Director focusing on compliance, investigations and technology at Control Risks, a global risk consultancy.

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