Extractive Payments Disclosure Control Director — Critical Minerals

The mandate

Royalties, production entitlements, taxes, licence fees, infrastructure contributions and in-kind transfers are recorded across mines, tax ledgers, procurement systems and joint-venture operators. The existing disclosure begins with general-ledger accounts, missing project attribution, payments made by operators and arrangements whose legal label differs from economic substance. New jurisdictional requirements make completeness and disaggregation a board-level exposure.

The engagement deliverable is an Extractive Payments Disclosure Control Architecture. It will establish government and project populations, payment-type definitions, control and operator boundaries, gross-versus-attributable treatment, currency and in-kind measurement, threshold aggregation, ledger and non-ledger capture, reconciliation, certification and correction. A change trigger will cover permits, operators, fiscal terms and new government-controlled counterparties.

Milestone one at week three provides population and requirement maps plus consequence-ranked gaps. Week seven closes data specifications, judgement rules and evidence standards. Milestone three in week twelve completes a shadow disclosure across selected mines. At week seventeen, accepted schedules, controls, issue register, trained owners and an unseen joint-venture payment scenario complete the output.

Acceptance requires Mine Finance and Tax to trace sampled payments to contract, recipient, project and settlement evidence; Legal to confirm the governed counterparty population; and Internal Controls to reperform thresholds, currency and operator treatment. The Controller signs only after client teams resolve fifteen unfamiliar cash and in-kind items without consultant-maintained mapping.

The client will provide entity and project registers, fiscal agreements, government-counterparty records, royalty and tax schedules, procurement data, joint-venture reports, bank payments, in-kind evidence, prior disclosures, controls and regulator comments. Management owns scope and disclosure conclusions. Legal advice, tax advice, anti-bribery investigation, valuation opinions, government negotiation, assurance and filing are excluded.

Why this is external work

No single function sees the full payment population: Tax sees levies, Procurement sees contributions, mine teams see in-kind transfers and operators hold joint-venture data. Independent specialists can design a complete evidence route across those boundaries without investigating conduct, interpreting law or becoming management’s disclosure preparer.

What you will own

• Establish complete governments, controlled entities, projects, concessions, operators and joint arrangements within disclosure scope.
• Classify taxes, royalties, fees, bonuses, production entitlements, dividends, infrastructure and in-kind transfers by requirement.
• Trace cash and non-cash payments through contracts, invoices, tax schedules, bank evidence and operator statements.
• Govern project attribution, recipient identity, thresholds, aggregation, currency conversion, gross treatment and corrections.
• Design controls for operator-provided data, government-controlled suppliers, offset settlements and non-ledger contributions.
• Exercise a changed operator, shared infrastructure payment, commodity transfer, disputed royalty and newly controlled recipient.
• Transfer disclosure ownership after a client-led shadow filing and accepted unfamiliar-payment case set.

Candidate qualifications

• Led government-payment or comparable transparency disclosure for a multinational mining, oil or extractive group.
• Built populations spanning governments, projects, operators, joint ventures, payment categories and in-kind transfers.
• Reconciled tax, royalty, procurement, treasury and operational records into controlled disaggregated disclosure.
• Resolved attribution, gross-versus-share, thresholds, currency and recipient questions under regulator or assurance scrutiny.
• Preserved boundaries among reporting, legal advice, tax advice, investigations, government affairs and independent assurance.
• Delivered disclosure controls that local and group owners sustained across later project and fiscal changes.

Non-negotiables

• The named director must lead Santiago workshops and travel to one material operating jurisdiction for evidence testing.
• Direct extractive-sector transparency reporting experience is required; sustainability narrative preparation alone is insufficient.
• No current relationship may involve disclosed governments, joint-venture operators, assurance firms or material licence advisers.
• Management retains legal and disclosure conclusions; investigation, negotiation, assurance and filing remain outside scope.

1. 49 words maximum. Describe a government payment that general-ledger screening failed to identify correctly.
2. 49 words maximum. How did you validate payments reported by a joint-venture operator outside your systems?
3. 49 words maximum. Which in-kind transfer would you use to test client ownership of the architecture?