An article in the Wall Street Journal (September 6, 2014) titled “Conflict Minerals Prove Hard to Track” descries the Commerce Department list of over 400 refiners with a statement that finding which smelters have minerals that can be tracked to funding militia in the Congo has been difficult. The reason is the small miners in the Congo and the untraceable sources of minerals such as gold traded in China. Given the difficulty in certifying smelters, how should US firms be expected to comply with the requirement of the 2010 Dodd-Frank act that requires firms to identify their sources and track conflict free content ? Is there an alternative to such bans of content from specific regions given the modern global supply chains where source materials are mixed ? What reasonable compliance schemes should companies be expected to have to comply with the intent of the law ?