ARTICLE
12 July 2016

Shining A Light On Payments To Governments: SEC Adopts ‘Publish What You Pay' Rule For Resource Extraction Issuers

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A&O Shearman

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A&O Shearman was formed in 2024 via the merger of two historic firms, Allen & Overy and Shearman & Sterling. With nearly 4,000 lawyers globally, we are equally fluent in English law, U.S. law and the laws of the world’s most dynamic markets. This combination creates a new kind of law firm, one built to achieve unparalleled outcomes for our clients on their most complex, multijurisdictional matters – everywhere in the world. A firm that advises at the forefront of the forces changing the current of global business and that is unrivalled in its global strength. Our clients benefit from the collective experience of teams who work with many of the world’s most influential companies and institutions, and have a history of precedent-setting innovations. Together our lawyers advise more than a third of NYSE-listed businesses, a fifth of the NASDAQ and a notable proportion of the London Stock Exchange, the Euronext, Euronext Paris and the Tokyo and Hong Kong Stock Exchanges.
On June 27, 2016, the US Securities and Exchange Commission adopted a final rule implementing Section 1504 of the Dodd-Frank Act.
Worldwide Corporate/Commercial Law

On June 27, 2016, the US Securities and Exchange Commission adopted a final rule implementing Section 1504 of the Dodd-Frank Act. The new rule will require resource extraction issuers to disclose payments they make to governments for the commercial development of oil, natural gas or minerals. The new rule will take effect for an issuer's first fiscal year ending on or after September 30, 2018, and will require disclosure of government payments information annually in a specialized disclosure report on Form SD, no later than 150 days after an issuer's fiscal year end.

View full memo, Shining a Light on Payments to Governments: SEC Adopts 'Publish What You Pay' Rule for Resource Extraction Issuers

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