United States
EITI Candidate


Breaking NewsSEC Reasserts US Leadership on Oil, Gas and Mining Transparency – December 11 2015

PWYP-US was launched in 2004 and has campaigned mainly on mandatory disclosures. These efforts culminated in the passage of the Cardin-Lugar provision in the Dodd-Frank Act of July 2010, which obliges all US listed companies to publish what they pay in the countries in which they operate. However, the law has yet to come into effect so PWYP-US is focusing its efforts on ensuring a swift and effecting implementation of the rule. PWYP-US also played a critical role in the advocacy push for the US to join EITI.

As a result of a recent lawsuit against the US Securities and Exchange Commission (SEC), the SEC released a proposed rule on December 11, 2015 and will hold a vote on a final rule no later than June 27, 2016.

On December 11th, PWYP-US will be live-tweeting during the proposed rule announcement – follow us @PWYPUSA

Section 1504 Background

  • Section 1504 Legislative History Timeline
  • Section 1504 Law Text
  • PWYP fact sheet on EU Accounting and Transparency Directives Nov2013
  • Fact Sheet on the August 2012 Implementing Rule for Section 1504
  • Fact Sheet on the July 2013 District Court Decision
  • Company Coverage Fact Sheet – This fact sheet analyzes the top 100 oil/gas and top 100 mining companies to determine how many are covered by mandatory disclosure requirements worldwide.
  • Recent PWYP-US SEC Submissions

  • For a comprehensive analysis of the companies subject to Section 1504 of the Dodd-Frank Act, click here to download the data. Read our submission to the SEC here.
  • Many of the world’s major oil, gas and mining companies support transparency. Read about Statoil’s 2014 payment disclosures, Tullow Oil’s voluntary disclosures of the last three years, as well as statements made by both companies supporting payment transparency.
  • PWYP-US Position Statement with recommendations for new 1504 rule.
  • Other Useful SEC Submissions

  • Investor support for Section 1504 is overwhelming. Investors with over $6.4 trillion in assets under management have written multiple letters to the SEC calling for a strong rule and arguing the importance of 1504 disclosures to investors. $6.4 trillion is greater than the GDP of every single country in the world, except the United States and China
  • The Department of State weighed in with the SEC on how project-level payment disclosure is a foreign policy priority
  • Read the ONE Campaign’s submission of 12 case studies‘ highlighting how transparency can lead to accountability and empower civil society
  • The Department of Interior has called on the SEC to deliver a strong 1504 rule
  • The Columbia Center on Sustainable Development and Jeffrey Sachs weigh in on the importance of project-level payment data for institutional investors
  • Open Oil provides evidence as to why no reporting exemptions should be allowed in the final 1504 rule
  • US oil company, Kosmos Energy, writes to the SEC on why they have voluntarily disclosed all of their project-level payment information
  • PWYP-Canada and PWYP-UK detail the mandatory disclosure requirements of Canada and the United Kingdom, calling on the SEC to produce a rule in line with the global standard
  • Duke University economist, Dr. Robert Conrad, writes to the SEC to debunk industry claims that Section 1504 will harm company competitiveness
  • The Global Call for Payment Transparency

    Civil society organizations from around the world have written in to the SEC detailing how they will use project-level payment information to hold companies and governments accountable in their countries. Many of these writers come from countries affected by the ‘resource curse’, a paradoxical situation in which countries that are rich in natural resources are some of the poorest in the world due to mismanagement and corruption. While the map below highlights letters from individual countries, a letter was also sent to the SEC that was signed by over 500 civil society organizations from 40 countries. A staggering demonstration of the worldwide support for payment transparency.

    Press Releases

    PWYP-US Applauds SEC Commitment to Swiftly Release Oil Transparency Rule – Oct 2, 2015

    PWYP-US and Global Witness call on the U.S. to Renew it’s Leadership on Landmark Transparency Law on the 5th Anniversary of Dodd-Frank – July 14, 2015

    13 Senators Call on SEC to Schedule Rulemaking for Transparency Law – May 7, 2014

    500 Civil Society Groups from 40 Countries Urge the U.S. to Maintain Leadership on Transparency in Oil, Gas and Mining – April 14, 2014

    PWYP-US Applauds EITI Acceptance of US Candidacy Application – March 20, 2014

    Coalition Urges SEC to Match Global Transparency Standard – March 19, 2014

    Investors and Congress Call on the SEC to Swiftly Deliver Strong Rules – Sept 3, 2013


    The Foundation is Shaking Beneath Big Oil’s House of Cards – “While API, the lobbying arm of Big Oil, has made a game of trumpeting the ‘parade of horribles’ that will supposedly result from Section 1504 disclosures, Dr. Conrad finds much more fiction than fact in their assertions.”

    Are you for Big Oil or Big Data? – “What most profoundly distinguishes American Petroleum Institute (API) from civil society organizations in resource-rich countries working to make a more transparent and accountable extractives sector? (Hint: the answer we’re looking for is not “the ability to pay for an army of high-priced lawyers” – although that works too.)…”

    Key Facts

    • US-listed BHP Billiton, the largest mining company in the world, voluntarily disclosed its 2014 project-level payments
    • 6 out of 10 of the largest mining companies by market cap are listed in the US.
    • In 2013 the US was the world’s third largest producer of oil.
    • Key resources: coal, copper, lead, zinc, gold, iron, oil and natural gas

    Key Contacts

    • Name: Jana Morgan
    • Email: jmorgan@pwypusa.org
    • Telephone: M: +1 703 795 8542 :: O: +1 202 496 1189