On 21 December, Ropes & Gray LLP published an alert saying that the European Commission has published its long-awaited global list of conflict-affected and high-risk areas, or CAHRA.  The relevant EU Regulation is concerned with sourcing from CAHRA anywhere in the world.  The article contrasts with the approach taken by the US Conflict Minerals Rule, which divides the world into the DRC region and everywhere else.  The EU Regulation does not designate specific countries or regions by name as CAHRA; instead, it contains a general principles-based definition of what it means to be a CAHRA.  The EU Commission engaged RAND Europe to prepare the CAHRA list, which includes 27 countries, more than what many industry participants expected. These countries and their listed sub-national areas are included in an Annex to the Alert. RAND Europe will review and update the CAHRA list quarterly.

I had omitted the following link (as it did not seem to generate much interest!), but it seemed time to add it again and say that, if you would like to make a (polite) gesture and help me with my removal and computer costs, I have a page at

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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