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If the UK Government meets the implementation deadline of 28 June 2013, then the United Kingdom will be one of the first EU Member States to implement the EU regulation on wholesale market integrity and transparency (REMIT). ...more
The U.S. Securities and Exchange Commission (SEC) recently published limited guidance on frequently asked questions relating to the SEC’s new Conflict Mineral Rules, which require U.S. issuers that manufacture or contract to...more
The Securities and Exchange Commission recently adopted final rules requiring disclosure of the use of “conflict minerals” by public companies, pursuant to a provision of the Dodd-Frank Wall Street Reform and Consumer...more
On May 30, the Division of Corporation Finance of the Securities and Exchange Commission issued responses to frequently asked questions regarding the disclosure of conflict mineral usage and payments by resource extraction...more
In contrast to joint venture issues relating to upstream oil and gas development, the topic of shareholders' agreements for Liquefied Natural Gas (LNG) liquefaction projects has not been covered to a similar extent in...more
On May 30, 2013, the Securities and Exchange Commission issued guidance related to the requirement that issuers disclose the use of conflict minerals in their products, as mandated by the 2010 Dodd-Frank Wall Street Reform...more
Introduction – Upstream Players -- In February 2013, after devaluating the official exchange rate of the Venezuelan Bolivar from VEB 4.3 to 6.3 per USD, the Venezuelan government set up the Complementary System of...more
FAQs clarify which entities and payments are subject to the final rules. On May 30, the Securities and Exchange Commission (SEC) released frequently asked questions (FAQs) providing guidance on certain aspects of its...more
On May 29, the DOJ and the SEC announced that a French oil and gas company will pay nearly $400 million to resolve allegations that the company made illegal payments through third parties to an Iranian official in exchange...more
The staff of the Division of Corporation Finance of the U.S. Securities and Exchange Commission recently issued long-awaited guidance on two of the more controversial provisions of the Dodd-Frank Act — the conflict minerals...more
FAQs address issues pertaining to the scope and application of the conflict minerals reporting requirement. On May 30, the staff of the U.S. Securities and Exchange Commission (SEC) issued interpretive guidance on the...more
Today I finalize my review of the Total SA (Total) Foreign Corrupt Practices Act (FCPA) enforcement action....more
On May 30, 2013, the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “SEC”) published Frequently Asked Questions (“FAQs”) regarding certain disclosures required under the Dodd-Frank Wall Street Reform...more
More than 50 investor groups released a statement expressing their disagreement with the lawsuit filed against the Securities and Exchange Commission (SEC) by the U.S. Chamber of Commerce, the National Association of...more
Yesterday I reviewed the facts surround Total SA’s (Total) lengthy bribery scheme to win contracts in Iran....more
On May 30, 2013 the SEC released 12 FAQs relating to disclosure regarding the use of conflict minerals, and nine FAQs relating to disclosure of payments by resource extraction issuers. Disclosure of the use of conflict...more
On May 29, French oil and gas company, Total SA, agreed to pay $398 million to settle US civil and criminal allegations that it paid bribes to win oil and gas contracts in Iran in violation of the Foreign Corrupt Practices...more
On May 29, 2013, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) announced agreements with Total S.A. (Total) to settle alleged Foreign Corrupt Practices Act (FCPA or the Act) violations for a...more
On May 30, 2013, the Securities and Exchange Commission’s Division of Corporation Finance released twelve Frequently Asked Questions in an effort to provide issuers with guidance on various aspects of Exchange Act Section 1...more
The Securities and Exchange Commission’s (the Commission or SEC) Division of Corporation Finance provided answers to questions regarding the Commission’s rules adopted in response to the Dodd-Frank Wall Street Reform and...more
For anyone who grew up in the 1960s, I am sure that you remember the touchstone slogan for Tareyton cigarettes, “I’d rather fight than switch”. ...more
This week the Securities and Exchange Commission (SEC) and the Department of Justice (DOJ) announced that France-based oil and gas company Total S.A. resolved Foreign Corrupt Practices Act (FCPA) charges by agreeing to pay a...more
On May 30, 2013, the SEC Division of Corporation Finance (the Division) issued responses to frequently asked questions (FAQs) on various aspects of the reporting requirements regarding conflict minerals originating in the...more
The SEC has issued twelve frequently asked questions, or FAQs, on the conflict minerals rules....more
The SEC has issued nine frequently asked questions, or FAQs, on the disclosure of payments by resource extraction issuers....more
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