SEC Adopts Expansive Disclosure Regime For Extractive Resource Issuers

Final Rule Implementing Dodd-Frank Extractive Resource Issuer Disclosure Requirements Applies to Government Payments Starting in October 2013; European Parliament May Consider an Even Broader Government Payment Disclosure Regime for All Industry Sectors.

On August 22, 2012, by a 2-1 vote¹, the U.S. Securities and Exchange Commission (the "Commission") adopted new Rule 13q-1 implementing the extractive resource issuer disclosure provisions in Section 1504 of the Dodd-Frank Wall Street Reform and Consumer Protection Act ("Dodd-Frank Act").²  Section 1504 amended the Securities Exchange Act of 1934 to require extractive resource issuers to make annual disclosures, in interactive data format, of payments made by the issuer, its subsidiaries, and entities under its control to a foreign government or the U.S. Federal Government for the commercial development of oil, natural gas, or minerals.³  Section 1504 further required that these disclosures provide information about