Stag Hunt: Anti-Corruption Disclosures Concerning Natural Resources

Abstract

The United States Securities and Exchange Commission (SEC) issued the rules for Disclosure of Payments by Resource Extraction Issuers for the third time in March 2021. This was prescribed by Section 1504 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (2010). These anti-corruption rules require resource extraction issuers listed on the U.S. stock exchanges to publicly report the type and total amounts of payments made for the "commercial development of oil, natural gas or minerals" to governments all over the world. This article argues that the long process of the creation of these rules, while frustrating for SEC officials and staff, can be conceptualized as a "stag hunt" involving other countries that host extraction companies on their stock exchanges.