The SEC's New Proposal on Resource Extraction Payments: A Deeper Dive

Companies in the mining and oil and gas industries are increasingly subject to requirements to disclose the payments they make to governments. In December 2015, the U.S. Securities and Exchange Commission published its proposed rule on the disclosure of “resource extraction payments,” implementing a directive of the Dodd-Frank Act of 2010. The Commission, under pressure from a court ruling, is now moving fast on this topic and will probably adopt a final rule later this year. This memorandum takes a detailed look at the proposal and how it compares to similar regimes around the world, as well as a prior version of the rule that was vacated by a federal court in 2013.