After almost a decade of attempting to issue similar rules, on December 16 the SEC adopted amendments that would require resource extraction companies to disclose payments made to foreign governments or to the U.S. federal government for the commercial development of oil, natural gas, or minerals.  By requiring disclosure at the national and major subnational political jurisdiction level, rather than the contract level, this version of the final rules mandates less disclosure than the SEC’s previous resource extraction disclosure rules.


This communication, which we believe may be of interest to our clients and friends of the firm, is for general information only. It is not a full analysis of the matters presented and should not be relied upon as legal advice. This may be considered attorney advertising in some jurisdictions. Please refer to the firm's privacy notice for further details.