Outside legal counsel will likely never put it so bluntly, but whenever a new regulation emerges one of their tasks is to determine how much wiggle room a company can count on.

Analysis of recent Securities and Exchange Commission rulemaking on the tracking and disclosure of the use of so-called โ€œconflict mineralsโ€ in the supply chain, however, has been less about looking for loopholes and more about trying to decipher its many ambiguities and gray areas that are open to interpretation.