Wall Street reform law creates foreign-payment legal hazards

On July 21, 2010, US President Barack Obama signed into law the Dodd-Frank Wall Street Reform and Consumer Protection Act.1 Section 1504 of the act requires resource extraction issuers to disclose to the Securities and Exchange Commission (SEC) both legal and illegal payments to foreign governments for the commercial development of oil, natural gas, and minerals.2 This will have four main impacts on oil and gas companies:• Although detailed rules need to be issued, at a minimum, the provision will require oil and gas companies to track extraction-related expenditures to governments on a company-wide basis and at a much more detailed level than previously required to be disclosed.&bul...

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