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SEC's Conflict Minerals Rules: What We Learned from 2013 and What Happens Next

Speaker(s): Beverly A. Wyckoff, Christopher T. McClure, Michael R. Littenberg
Recorded on: Oct. 24, 2014
PLI Program #: 61452

Beverly advises Dover Corporation companies on regulatory compliance matters, including trade compliance, conflict minerals, cyber security and government contracting.  She oversees implementation of sanctions compliance programs across Dover’s global operating companies, and works with the companies on implementation and maintenance of key trade controls initiatives.  She also provides support on geographic expansion activities, including establishing entities in new markets to meet bid and customer requirements or facilitate local operations.

Before joining Dover, Beverly was at Axiom Law, supporting clients on compliance programs, conflict minerals, cybersecurity, and import / export and ITAR programs. She also previously served as Vice President, General Counsel of FirstGroup America and Laidlaw Transit, the largest private transportations companies in North America, and was with Zenith Electronics Corporation, including five years as Vice President and General Counsel. She helped Zenith navigate its Chapter 11 bankruptcy and reestablish itself as a technology company through the development of an IP licensing program.  Prior to Zenith, Bev worked with a telecommunications start-up, and managed tax exempt financing with US and Japanese banks.

Bev is a graduate of Yale University and holds a law degree from the University of Miami (Florida) School of Law.

Christopher McClure leads the Midwest Forensic Practice of Crowe Horwath LLP where he assists companies and their counsel in dealing with various regulatory issues and complex disputes and investigations. Chris leads the efforts of Crowe to assist clients with the new Conflict Minerals reporting requirements under Dodd-Frank and is a frequent speaker and author. He is a CPA, CFE, experienced testifier, and has an MBA from the Kellogg School of Management. Prior to Crowe, Christopher was with Navigant Consulting and Arthur Andersen in Chicago and Texas.

Michael R. Littenberg, a partner in the New York office, specializes in corporate finance and ongoing securities law compliance, mergers & acquisitions, and venture capital transactions.

Michael is a frequent speaker at conferences and seminars, has authored numerous articles and is frequently quoted as an expert in the business and specialty press on topics pertaining to his areas of expertise. Michael is listed in Who's Who in Securities Law and in New York Super Lawyers for securities and corporate finance. He received his J.D., magna cum laude, from Tulane University Law School, where he was an editor of the Tulane Law Review and a member of the Order of the Coif, and his B.S. from Indiana University.

Selected Publications

“Additional Supply Chain Disclosures by U.S. Public Companies Proposed,” SRZ Client Alert, July 8, 2014 (co-author); republished in Westlaw Journal – Securities Litigation & Regulation, August 2014

“Breaking News — Motion to Stay Conflict Minerals Rule Denied — June 2 Filing Deadline Remains In Effect,” SRZ Client Alert, May 14, 2014 (co-author)

“SEC Publishes Statement on Conflict Minerals Reporting – Important New Guidance on Timing, Product Labeling and Audit Requirements,” SRZ Client Alert, April 30, 2014 (co-author)

Selected Speaking Engagements

“Conflict Minerals,” ISM Risk Management Summit, July 2014

“Integrating OFAC and FCPA Compliance with Your Conflict Minerals Compliance Program — Strategies for Mitigating Risk,” SRZ Advanced Conflict Minerals Rule Compliance Series Webinar, July 2014

“The First Year of Compliance: Lessons Learned and Recommendations for 2014,” Marcus Evans 2nd Conflict Minerals Reporting and Supply Chain Transparency Conference, June 2014

Other Distinctions

  • New York Super Lawyers — New York Metro Top 100 Lawyers (2012-13)
  • New York Super Lawyers — Securities and Corporate Finance (multiple years)
  • Investment Dealers' Digest Who's Who in Securities Law
  • Deal of the Year, U.S. Public Debt (Marine Money, 2010)
  • High Yield Bond Deal of the Year (International Financial Review, 2009)
  • Complinet Editorial Advisory Board
  • Law360 Corporate Finance Advisory Board (Past)
  • Chair, Manhattan Chamber of Commerce (Past)
  • Annual Fund Chair, Tulane Law School (Past)
Bar Admissions 
  • New York
  • Tulane University Law School, J.D., magna cum laude, 1990
    • Associate Editor, Tulane Law Review
    • Order of the Coif
  • Indiana University, B.S., 1987 


  • Securities & Capital Markets
  • Mergers & Acquisitions
  • Real Estate Capital Markets & REITs
  • Private Equity
  • PIPEs
  • Financial Institutions