7. Latest updates (November 2017)

In a similar vein to the US Dodd-Frank Act of 2010, on March 16, 2017, the European Union adopted a regulation aimed at curbing trade in the four metals - tin, tantalum, tungsten and gold.

The regulation provides for a "duty of care", i.e. the obligation for companies to ensure that their imports of ores and metals covered by the regulation and reaching certain thresholds come exclusively from responsible sources. The regulation will apply directly to European importers (between 600 and 1,000 companies) and indirectly to around 500 smelters and refineries, whether or not they are located in the European Union.

The regulation introduces a genuine risk management approach, as companies will have to assess the degree of risk associated with their sourcing of raw materials from a given conflict region, and evaluate the likelihood of these raw...