# GAO Conflict Minerals Report 2024
> [!abstract] 🏛️ Official government report
> **Issued by:** [[Government Accountability Office]], the auditing arm of Congress · **Legal basis:** the reporting mandate in Dodd-Frank §1502 · **Date:** October 7, 2024
[[Government Accountability Office]], **GAO-25-107018**, *Conflict Minerals: Peace and Security in Democratic Republic of the Congo Have Not Improved with SEC Disclosure Rule*, **7 October 2024**. The final GAO report under the Dodd-Frank Section 1502 statutory mandate.
The single most important document in the current fight over [[Dodd-Frank Section 1502]], and one that is being read more strongly than it was written.
## What it concluded, in its own words
- The rule **"has not reduced violence in the Democratic Republic of the Congo"** and **"has likely had no effect in adjoining countries."**
- It was **"associated with a spread of violence, particularly around informal, small-scale gold mining sites"** — the stated mechanism being that armed groups shifted competition toward gold, which is more portable and harder to trace than 3T.
- Offsetting: the rule **"has encouraged companies to improve reporting of conflict minerals' sources by tracking the minerals' chain of custody"** and raised international awareness of armed-group financing.
- **1,017 companies filed in 2023** — the first increase since 2014 — but about **62% of those conducting due diligence could not determine whether their minerals originated in covered countries.**
## The method, and where it is fragile
ACLED conflict-event data from 2004 onward, DHS survey data on sexual violence, linear probability and count models plus **synthetic control**, with controls for territory, time, mineral prices, historical violence, spatial proximity and precipitation. A representative sample of 100 filings was reviewed.
Two weaknesses matter:
**ACLED event counts carry reporting-density bias.** Better-covered areas record more events, and coverage of eastern Congo improved substantially over the study period — which can manufacture an apparent increase in violence.
**The counterfactual is intrinsically hard.** Synthetic control on conflict outcomes in a region absorbing simultaneous major shocks — M23 in 2012–13, the ADF, Kamuina Nsapu, ISCAP, M23 again from 2021 — is fragile. **GAO reports association, not causal identification.** The phrase "was associated with a spread of violence" is being read causally by nearly everyone using it.
## How it is being used
It has become the anchor citation of the repeal campaign, and GAO did not recommend repeal.
- Law-firm analysis in May 2025 argued the filing season might be "the swan song" for the rule, citing GAO's conclusions and noting that Exchange Act §13(p) lets the President **waive the requirement for two years on national-security grounds or terminate it entirely**.
- The **National Association of Manufacturers**, petitioning the State Department on 3 April 2026 to invoke the sunset, quoted the "associated with a spread of violence" line directly.
- The advocacy side treats the **chain-of-custody finding** as the operative one.
The report is doing double duty: a genuine negative-result evaluation, and the evidentiary predicate for a deregulatory campaign it did not call for. That is worth naming, because it is the ordinary fate of careful government evaluation in a contested policy fight — and because the finding that **gold got worse while 3T got better** is corroborated independently by the academic literature on both sides.
## See also
[[Dodd-Frank Section 1502]] · [[Government Accountability Office]] · [[Laura Seay]] · [[Conflict Minerals Supply Chain]] · [[Conflict Minerals Hub]]