global witness @ 11th Floor 777 6th Street, NW Washington, DC 20001 +1202-827-8673
[email protected] @Global_Witness www.globalwitness.org March 12, 2020 Vanessa A. Countryman Secretary, Securities and Exchange Commission 100 F Street NE, Washington, DC 20549-1090 Re: Global Witness data handbook Dear Secretary Countryman, Global Witness welcomes the opportunity to provide comments on the Commission's proposed rule implementing Section 1504 ofthe Dodd-Frank Wall Street Reform and Consumer Protection Act. In support of international efforts to combat corruption in resource-rich countries, Global Witness and Resources for Development Consulting published 'Finding the Missing Millions' in 2018, a handbook for using payment data to hold governments accountable for natural resource revenues. The handbook is designed to encourage civil society actors, journalists and other stakeholders to use payment data, and to produce analyses that are reliable and influential. The handbook includes ten different methodologies for using payment data from oil, gas and mining projects. Each methodology features several 'real life' case examples to illustrate how this can be done. Since publication, Global Witness has carried out data training events based on the handbook methodologies with civil society activists and/orjournalists in Nigeria, Indonesia, Senegal, Myanmar, South Africa, the UK, US and France. The handbook focuses on the use of contract-based, project-level payment data. Corruption, poorly negotiated deals, shortfalls in payments and financial mismanagement occur frequently at the contract level. We believe therefore that it is crucial for payments to be transparent atthe contract level, and that media and civil society watchdogs are empowered with the data and tools to detect and deter such practices.