About | HeinOnline Law Journal Library | HeinOnline Law Journal Library | HeinOnline



1 Chi. J. Int'l L. Online 1 (2021-2022)

handle is hein.journals/cojloinllw1 and id is 1 raw text is: 















    Stag   Hunt: Anti-Corruption Disclosures Concerning
                              Natural Resources
                                   Aleydis  Nissen*


                                      Abstract

      The  United  States Securities and Exchange Commission   (SEC)  issued the ru/es 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 ru/es require resource extraction issuers listed on
the U.S. stock exchanges to publicly report the type and total amounts ofpayments made for the
commercial development of oil, naturalgas or minerals togovernments all over the world. This
Article argues that the long process of the creation of these ru/es, while frustrating for SEC
offiials and sta, can be conceptualized as a stag hunt involving other countries that host
extraction companies on their stock exchanges.


Aleydis Nissen is a postdoctoral researcher at Leiden Law School, Vrije Universiteit Brussel
(sponsored by FWO  Postdoc grant 74910) and Universit6 libre de Bruxelles (sponsored by
F.R.S.-FNRS Charg6 de Recherche Fellowship grant FC 38129). Recently, she won the Andres
Bello (.B. Scott) Prize in International Law of the Geneva-based Institut de Droit International for
other research. She wants to thank Nicole Briones, Susan Cleary, Kathy Luo, Maria O'Keeffe,
Amber  Stewart, Leonie van Moorsel, and Kaylee Yocum for their comments and support. Any
mistakes remain, of course, the sole responsibility of the author.


1