In 2002, the UN Panel of Experts on Illegal Exploitation of Natural Resources and Other Forms of Wealth of the Democratic Republic of the Congo issued its final report.2 In it, the Panel included a list it had compiled of companies involved in the war economy of the Democratic Republic of the Congo (DRC). The Panel, which had been mandated by the Security Council to examine the DRC war economy and make recommendations about sanctions and other measures, stated that ‘[b]y contributing to the revenues of the elite networks, directly or indirectly, those companies and individuals contribute to the ongoing conflict and to human rights abuses’.3 The Panel appended to its report several lists: one identified ‘companies on which the panel recommends placing financial restrictions’ and a second consisted of names of ‘persons for whom the Panel recommends travel and financial restrictions’. A third list identified businesses alleged to be ‘in violation of the OECD Guidelines for Multinational Enterprises’.4