Reasonable Country of Origin Inquiry (RCOI)
A documented, good-faith inquiry into the origin of 3TG, with supplier response rates maximized through automated multilingual outreach and chase sequences.
The most rigorous 3TG/EMRT compliance program a manufacturer can run.
Responsible Minerals Compliance Engine delivers a complete, audit-ready conflict-minerals program — supplier survey campaigns, CMRT/EMRT data validation, smelter conformance checks against the RMI list, and a filed SEC Form SD — with AI as the internal production engine and a qualified reviewer at the sign-off chokepoint.
Every element of SEC Rule 13p-1 & OECD Due DiligenceCMRT/EMRT validation against RMI RMAP listMultilingual supplier outreach & chase sequencesQualified reviewer sign-off on every program5-business-day SLA
Why programs fail
A single low response rate can undermine your entire filing.
A manufacturer's conflict-minerals program is only as strong as its supplier survey campaign. Miss a critical smelter, fail to validate a CMRT, or let response rates stall below 60% — and the RCOI becomes indefensible, inviting auditor scrutiny and SEC questions.
Most companies run this by hand, from spreadsheets, once a year. The RMI template changes, the smelter list updates, and the filing deadline does not move. That is exactly where compliance gaps hide.
Responsible Minerals Compliance Engine exists to close that gap with a single, exhaustive standard applied identically to every program.
39%
supplier response rate in a real FY2026 Form SD filing
The benchmark
Measured against the letter of the regulation — rule by rule.
We do not summarize the law and hope. Every program is scored against a versioned rule pack tied to the exact text of SEC Rule 13p-1, the OECD Due Diligence Guidance, and the RMI RMAP standard. These are the provisions each program is held to.
Five-step due diligence framework
Step 1: Manage company systems; Step 2: Identify and assess risks in the supply chain; Step 3: Design and implement a strategy to respond; Step 4: Carry out independent third-party audit; Step 5: Report annually — all evidenced.
Smelter/refiner conformance check
Every smelter reported in CMRTs is matched against the current RMI RMAP conformant list; non-conformant or unknown smelters are flagged for risk assessment.
Template validation
All returned CMRT and EMRT templates are parsed and validated for completeness, consistency, and schema compliance per the latest RMI template version.
Importer due diligence
For EU importers of 3TG, the program includes the additional obligations of supply chain due diligence, risk management, and annual reporting to competent authorities.
Extended minerals coverage
The program supports EMRT for cobalt, mica, copper, natural graphite, lithium, and nickel, aligning with the expanded scope of the EU Battery Regulation.
How a program is built
Intake to reviewer release, with deterministic gates the AI cannot overrule.
AI extracts and drafts. Deterministic rules — running as code, outside the model — decide what is complete. A qualified reviewer signs every release. That order is never reversed.
01
Compliance Gap Scan
Upload your supplier list and prior-year filing. We return a free completeness read: which statutory elements and supplier responses you already have, and which are missing.
02
Supplier survey campaign
As your authorized agent, we distribute CMRT/EMRT templates to your suppliers in their preferred language, with automated chase sequences to maximize response rates.
03
Data extraction & validation
Returned templates are parsed by AI; smelters are matched against the RMI RMAP list; country-of-origin and CAHRA risk flags are applied.
04
Deterministic completeness gates
Response rate thresholds, smelter conformance checks, template schema validation, and OECD step completion are verified. Any failure blocks release.
05
Qualified reviewer release
A compliance specialist reviews the exception queue and signs the release. High-risk or high-value programs route to attorney review first.
06
Delivery
You receive the completed program: filed Form SD, Conflict Minerals Report, supplier response matrix, smelter validation log, audit trail, and a 60-day calendar for next season.
The bar we hold
Rigor you can measure.
100%
Reviewer-released
No program ships without a qualified human signature.
5 days
Standard SLA
From complete intake to released program.
<1%
Critical-defect target
Tracked against a gold-standard program library.
4
Regulatory frameworks covered
SEC Rule 13p-1 · OECD Guidance · EU CMR · EU Battery Regulation.
Why Responsible Minerals Compliance Engine
Built to be the most thorough option a manufacturer has.
Documentation-complete, by design
The deliverable is completeness itself — every regulatory element and supplier response accounted for or explicitly exception-coded. Nothing is left implicit.
Deterministic, not vibes
The gates that decide completeness are code, not a model's opinion. A drafting error cannot slip past a regulatory requirement.
In its lane, on purpose
We prepare documentation and run surveys as your clerical agent. We never give legal advice, make compliance determinations, or sign filings on your behalf.
Engagement
Flat fee, per managed program. No contingency, ever.
Simple, predictable, and aligned with a compliance standard — not a cut of any recovery.
- A free Compliance Gap Scan before you commit — see exactly what is missing.
- One flat fee per managed program; disclosed pass-through supplier survey costs.
- Optional fixed-fee attorney review for high-risk or complex supply chains.
- Optional Multi-Regime Add-on for EU CMR and Battery Regulation coverage.
FAQ
Questions, answered precisely.
Is Responsible Minerals Compliance Engine a law firm?
No. Responsible Minerals Compliance Engine, a service of Your Deputy, Obuke LLC, provides documentation-completeness services. It is not a law firm, does not provide legal advice, and does not represent you in any legal matter. Attorney review is available and recommended for complex or high-risk filings.
Do you contact my suppliers or make compliance decisions?
We contact suppliers only as your authorized agent to distribute surveys and chase responses. We never make compliance determinations or sign filings on your behalf. You remain the responsible party for all regulatory submissions.
What makes a program 'complete'?
Completeness is defined by the regulation: a documented RCOI, validated CMRT/EMRT data, smelter conformance check against the RMI list, OECD due diligence steps evidenced, and a draft Form SD ready for counsel review. Deterministic gates enforce each one before release.
How fast is it?
The standard SLA is five business days from complete intake to a reviewer-released program. The free Gap Scan is returned much sooner and tells you exactly what is still needed.
How are you priced?
A flat fee per managed program, plus disclosed pass-through survey costs. No contingency and no percentage of any recovered amount or sale proceeds.
See what's missing before it costs you a filing.
Start with a free Compliance Gap Scan. Send your supplier list and prior-year filing and we'll return a completeness read against every element of SEC Rule 13p-1 and the OECD Guidance.
Documentation-completeness service · not legal advice · you remain the responsible filer.