Deputy Attorney General Rod Rosenstein announced the addition of a new Department of Justice (DOJ) Foreign Corrupt Practices Act (FCPA) policy, titled the FCPA Corporate Enforcement Policy. The new policy, which was...more
ANTICORRUPTION DEVELOPMENTS – SBM Offshore N.V. Agrees to Pay $238 Million to Resolve DOJ FCPA Enforcement Action - On November 29, 2017, SBM Offshore N.V. (SBM), a Netherlands based company specializing in the...more
On July 27, 2016, the U.S. Securities and Exchange Commission (SEC) adopted revised rules requiring resource extraction issuers to disclose payments made to governments for the commercial development of oil, natural gas, or...more
New rules issued by the U.S. Securities and Exchange Commission (SEC) that require resource extraction issuers to disclose payments made to U.S. and foreign governments for the commercial development of oil, natural gas or...more
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...more
On December 11, the Securities and Exchange Commission proposed Rule 13q-1 of the Securities Exchange Act of 1934 (Exchange Act), often referred to as the “resource extraction rule,” which would require an issuer to disclose...more
SEC/CORPORATE SEC Division of Corporation Finance Issues New C&DIs on FAST Act - As previously reported, President Obama signed into law the Fixing America’s Surface Transportation Act (FAST Act) on December 4. The...more
On December 11, 2015, the U.S. Securities and Exchange Commission (SEC) proposed new rules pursuant to Section 1504 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (“Dodd-Frank Act”), which, if...more
After striking out in its first attempt to formulate a proposed rule to implement the extractive industry payments provision of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”), the Securities and...more
On December 11, the SEC re-proposed rules requiring disclosure of government payments by resource extraction issuers. The proposed rules will require resource extraction issuers to disclose payments made to the U.S. federal...more
On October 2, the Securities and Exchange Commission (“SEC”) filed a schedule with the U.S. District Court for the District of Massachusetts providing details as to when the agency will seek to issue a final rule on revenue...more
On January 2, the Securities and Exchange Commission (“SEC”) filed its brief (.pdf) in the lawsuit brought by the U.S. Chamber of Commerce, the American Petroleum Institute (“API”), the National Foreign Trade Council, and the...more