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FINANCIAL & CAPITAL MARKETS

Critical mineral supply chain compliance

Critical mineral supply chain compliance is becoming a direct liability issue for Financial & Capital Markets firms, not just an ESG footnote. The U.S. Securities and Exchange Commission's climate-related disclosure rules and the European Securities and Markets Authority's SFDR supply chain guidance both create explicit downstream obligations for asset managers and lenders with exposure to mining, processing, or battery-supply portfolios. Compliance teams are currently mapping counterparty relationships and vendor contracts against these disclosure standards to determine what qualifies as a material dependency before reporting deadlines arrive.

Watch

  • SEC climate disclosure rule: which supply chain dependencies trigger Scope 3 reporting
  • ESMA SFDR guidance on 'principal adverse impacts' applied to mineral-intensive holdings
  • U.S. Department of the Treasury sanctions exposure from restricted-origin mineral inputs
  • IRA domestic content requirements and lender due diligence obligations for financed projects

Recent material activity in Financial & Capital Markets

Active monitoring in place across Financial & Capital Markets. Material developments related to critical mineral supply chain compliance will appear here as they are published.