The injustices inherent in the global climate crisis are deeply connected to the historical legacy of imperial colonialism. The Global North has built its economies and power by offloading many costs and risks to Global South countries. The Global North continues to leverage asymmetric power dynamics in the global financial architecture to use the Global South for its resources without adequate compensation, often producing negative environmental and social impacts at the local level and human rights violations.17 These disparities have contributed to the Global South's enormous climate investment gap. Wealthy countries have pledged billions of dollars toward climate finance for Global South countries, but at the same time, have consistently failed to appropriate those funds, with no formal accountability mechanism in place.18 Public finance, consisting of financial contributions from governments and public institutions, is inadequate to close the financing gap between the Global North and the Global South in addressing climate change issues, and most finance provided to the Global South is in the form of loans. Major problems with private finance exist as well, which require effective regulation to yield equitable, safe, and racially just climate investment. The United States plays a pivotal role in climate finance. Notably, U.S. policymakers have contributed substantially to public finance policies that have created the current intractable sovereign debt spirals, and they also influence global private climate investment flows through regulation of major U.S. financial institutions, some of the largest in the world. Recent progress in climate financial regulation by U.S. regulators, however, has opened the door for new thinking and, hopefully, new opportunities to improve and expand private financial flows toward climate mitigation and resilience.
Despite these developments, the voices of the Global South remain largely unheard within the global financial architecture, often due to structural design. For example, Global North countries hold disproportionately high allocations of International Monetary Fund (IMF) Special Drawing Rights, which grant them outsized voting control for future allocations.20 There is also a need for more leadership opportunities and inclusive engagement with community groups from the Global South on climate finance and regulation. Host communities in the Global South rarely receive adequate transparency or the ability to influence and coordinate climate investment choices that greatly affect them. This document aims to continuously emphasize the Global South's important role in climate finance discourse and the need to foster robust climate financial regulations to ensure accountability, inclusivity, and transparency.
In 2023, COP2821—hosted by the United Arab Emirates, one of the world’s leading oil producers—fell well short of discussing the types of transformational changes needed to restructure the global financial architecture. Still, one of the most significant announcements to come out of COP28 was the formalization of a climate change loss and damage fund for vulnerable countries.22 The Loss and Damage Fund (discussed further in Section 4) will be hosted by the World Bank for an interim period, with contributions not limited to governments; private investors and corporations (fossil fuel corporations in particular) are encouraged to contribute to the LDF. Many critics object to the World Bank hosting the LDF and are pressing for an alternative permanent host less controlled by the Global North.23 Some observers have promoted the idea of taxes or mandatory contributions from corporations in proportion to profits gained and environmental damage caused.24 The meetings concluded with an insufficient commitment to “transition away” from fossil fuels,25 a stark difference from the initial draft phrasing—to “phase out” fossil fuels—which would have better captured the necessity of moving away from fossil fuels entirely.
Despite these developments, the voices of the Global South remain largely unheard within the global financial architecture, often due to structural design. For example, Global North countries hold disproportionately high allocations of International Monetary Fund (IMF) Special Drawing Rights, which grant them outsized voting control for future allocations.20 There is also a need for more leadership opportunities and inclusive engagement with community groups from the Global South on climate finance and regulation. Host communities in the Global South rarely receive adequate transparency or the ability to influence and coordinate climate investment choices that greatly affect them. This document aims to continuously emphasize the Global South's important role in climate finance discourse and the need to foster robust climate financial regulations to ensure accountability, inclusivity, and transparency.
In 2023, COP2821—hosted by the United Arab Emirates, one of the world’s leading oil producers—fell well short of discussing the types of transformational changes needed to restructure the global financial architecture. Still, one of the most significant announcements to come out of COP28 was the formalization of a climate change loss and damage fund for vulnerable countries.22 The Loss and Damage Fund (discussed further in Section 4) will be hosted by the World Bank for an interim period, with contributions not limited to governments; private investors and corporations (fossil fuel corporations in particular) are encouraged to contribute to the LDF. Many critics object to the World Bank hosting the LDF and are pressing for an alternative permanent host less controlled by the Global North.23 Some observers have promoted the idea of taxes or mandatory contributions from corporations in proportion to profits gained and environmental damage caused.24 The meetings concluded with an insufficient commitment to “transition away” from fossil fuels,25 a stark difference from the initial draft phrasing—to “phase out” fossil fuels—which would have better captured the necessity of moving away from fossil fuels entirely.
The $700 million pledged for the LDF is far insufficient in the face of $400 billion in annual damages being accrued by Global South countries.26 On top of those recovery costs, Global South countries with emerging and developing economies will need more than $2 trillion annually in clean energy investment by 2030 to be on track to reach the goals of the Paris Agreement,27 and those sums will largely need to flow through public, private, and blended finance mechanisms from the Global North. An immense financing gap remains, and existing efforts are too often extractive or create collateral harm, including through the saddling of countries with untenable debt. As much as possible, climate finance should come in the form of grants, not loans, to avoid further indebtedness. This paper aims to explore ways that U.S. policymakers can help close the financing gap and enact reforms that account for the unique challenges faced by Global South nations in accessing safe, equitable, and racially just climate finance and redressing the harms of existing financial flows. Shifts in our approach to financial regulation will be critical to achieving those goals. Our focus is on how U.S. policymakers should: • Reform climate financial regulation of private markets and firms (Section 2); and • Advocate for reforms to global trade rules (Section 3). We also discuss what U.S. policymakers should do to: • Support a more equitable global public finance architecture (Section 4); and • Explore and support other financing mechanisms that have been put forward to bridge the climate finance gap (Section 5). Optimum solutions will require policymakers to consider reforms in each of those areas and their interaction. The writers’ expertise lies primarily in private financial regulation and global trade; in these areas, we propose novel policy solutions. On public finance, we largely summarize the proposed reforms put forth by other experts and policymakers.
Our recommendations, discussed in more detail throughout the paper, include the following: The U.S. Department of the Treasury (Treasury), with other agencies as appropriate: • Treasury should support international efforts to achieve a global standard for science-aligned mandatory corporate transition plans and push large U.S. corporations and financial firms to reduce their absolute Scope 1, 2, and 3 emissions and commit to providing equitable, safe, and racially just climate investment and aid in the Global South. • Treasury should strengthen its Principles for NetZero Financing and Investment by stating that financial firms need to meet their commitments by reducing emissions and respecting human rights, and not through buying carbon credits, which often lead to human rights abuses and environmental and racial injustices in the Global South. Treasury should call on financial institutions to have net-zero plans aligned to the Principles. • The Financial Stability Oversight Council (FSOC) should designate high-emissions non-bank financial companies (NFCs), including large insurers, asset managers, and private equity firms, as “systemically important” and therefore subject to enhanced supervision by the Federal Reserve
Our recommendations, discussed in more detail throughout the paper, include the following: The U.S. Department of the Treasury (Treasury), with other agencies as appropriate: • Treasury should support international efforts to achieve a global standard for science-aligned mandatory corporate transition plans and push large U.S. corporations and financial firms to reduce their absolute Scope 1, 2, and 3 emissions and commit to providing equitable, safe, and racially just climate investment and aid in the Global South. • Treasury should strengthen its Principles for NetZero Financing and Investment by stating that financial firms need to meet their commitments by reducing emissions and respecting human rights, and not through buying carbon credits, which often lead to human rights abuses and environmental and racial injustices in the Global South. Treasury should call on financial institutions to have net-zero plans aligned to the Principles. • The Financial Stability Oversight Council (FSOC) should designate high-emissions non-bank financial companies (NFCs), including large insurers, asset managers, and private equity firms, as “systemically important” and therefore subject to enhanced supervision by the Federal Reserve
| fema_after-the-fire_fact-sheet.pdf |
• The Treasury should push for and support the quantifiable goals and timelines in the World Bank’s proposed Evolution Roadmap so that the institution can better address the multiple crises facing Global South countries according to the particular needs of the people and communities affected. • Treasury should set green, social, and sustainability bond standards or principles, which could include reduced interest rates for certified public projects domestically and abroad and third-party verification mechanisms. • The Treasury should request to be an observer for the Green Bond Principles and encourage the expansion of the Green Bond membership and observers list to more countries and organizations in the Global South to promote inclusivity and transparency. • For debt relief mechanisms, the Treasury should prioritize and explore grants, traditional debt relief, comprehensive debt restructuring, and concessional finance before considering debt-for-nature swaps. Debt-for-nature swaps may still be useful in contributing to a small, tailored portion of the financing pool for climate-vulnerable, low-income/high-debt countries in the Global South. • The Treasury should facilitate discussions with Global South countries to provide technical assistance and promote technology transfer to help Global South countries develop and add value to their raw materials and industrialize in a climate-friendly manner. • Treasury along with the Department of Justice and the Securities and Exchange Commission should encourage covered U.S. corporations to comply fully with any and all obligations under the EU Corporate Sustainability Due Diligence Directive. U.S. Banking Regulators • U.S. banking regulators should closely oversee the alignment between large banks’ climate pledges, net-zero transition plans, and internal strategies, as indicated in their “Principles for Climate-Related Financial Risk Management for Large Financial Institutions.
• U.S. banking regulators should require all large banks and NFCs under their supervision to develop and implement net-zero transition plans that include measures to provide equitable, safe, and racially just climate investment and aid in the Global South. • U.S. banking regulators should impose a capital surcharge on systemically important global banks and designated non-bank financial companies based on their financed and facilitated emissions.
• U.S. banking regulators should require all large banks and NFCs under their supervision to develop and implement net-zero transition plans that include measures to provide equitable, safe, and racially just climate investment and aid in the Global South. • U.S. banking regulators should impose a capital surcharge on systemically important global banks and designated non-bank financial companies based on their financed and facilitated emissions.
| flood_fima_fact_sheet_advice_salvaging.pdf |
U.S. Securities and Exchange Commission (SEC) • The SEC should hold corporations accountable for failing to report or inaccurately reporting their climate and environmental impacts and human rights violations in the Global South, and corporations should be required to disclose their engagement and partnership work plans with local communities. • The SEC should look to the International Sustainability Standards Board (ISSB) climate disclosure regime as a minimum baseline for all large registrants, and work with ISSB and other market regulators on international harmonization. • The SEC should implement a mandatory net-zero transition plan disclosure regime for large U.S. public corporations and financial firms that have made public net-zero commitments. • The SEC’s disclosure rules should be updated to incorporate impacts on local communities, including those related to climate vulnerability, environmental damage, and human rights abuses, and any grievance redress mechanisms in place to remedy harms. • The SEC should work to reverse the trend of capital migration from public equities markets to less regulated private markets and require climate-related disclosures for private debt issuances. • Accounting, corporate, disclosure, and audit regulators in the United States and around the world should require incorporation of environmental liabilities' projected costs and asset retirement obligations in financial reporting. That would encourage corporations to maintain sufficient capital to cover those costs and allow investors to account for them, particularly in the Global South, where the lack of remediation by Global North corporations is still especially prevalent.
• The CFTC should establish a benchmark for high-quality carbon credit derivatives, which are based on underlying carbon credits that are independently verified as providing genuine carbon removal, permanence, and additionality. Such credits must also be created with robust community engagement and respect for the rights of local Indigenous communities, to minimize the potential for abuse of human rights and negative environmental, social, and economic impacts.
• The FASB and PCAOB should create and enforce a standardized accounting and audit framework to account for, disclose, and verify climate-related impacts on financial statements to ensure transparency within the global markets. • The FASB should create, and the SEC enforce, a standardized accounting methodology for voluntary carbon credit expenditures. This would enable investors to make informed decisions about corporations purchasing credits.
• Congress should adopt a law similar to the EU Corporate Sustainability Due Diligence Directive, which would require corporations to identify actual and potential risks to human rights and the environment within their value chains and establish procedures to mitigate those risks or face financial penalties. • Congress should substantially increase funding for safe, equitable, and racially just climate investment in the Global South through direct aid, concessional finance without indebtedness, and other forms of support.
• The U.S. Trade Representative should promote a “Climate Peace Clause” (i.e. a commitment by governments to refrain from using outdated trade rules to challenge one another’s climate policies) to protect climate-related financial regulation from being challenged at the World Trade Organization (WTO) or through new and existing trade agreements. • The U.S. Trade Representative should work to remove Investor-State Dispute Settlement (ISDS) provisions from existing U.S. trade agreements and investment treaties to promote environmental protection and sustainable, equitable trade practices.
• The CFTC should establish a benchmark for high-quality carbon credit derivatives, which are based on underlying carbon credits that are independently verified as providing genuine carbon removal, permanence, and additionality. Such credits must also be created with robust community engagement and respect for the rights of local Indigenous communities, to minimize the potential for abuse of human rights and negative environmental, social, and economic impacts.
• The FASB and PCAOB should create and enforce a standardized accounting and audit framework to account for, disclose, and verify climate-related impacts on financial statements to ensure transparency within the global markets. • The FASB should create, and the SEC enforce, a standardized accounting methodology for voluntary carbon credit expenditures. This would enable investors to make informed decisions about corporations purchasing credits.
• Congress should adopt a law similar to the EU Corporate Sustainability Due Diligence Directive, which would require corporations to identify actual and potential risks to human rights and the environment within their value chains and establish procedures to mitigate those risks or face financial penalties. • Congress should substantially increase funding for safe, equitable, and racially just climate investment in the Global South through direct aid, concessional finance without indebtedness, and other forms of support.
• The U.S. Trade Representative should promote a “Climate Peace Clause” (i.e. a commitment by governments to refrain from using outdated trade rules to challenge one another’s climate policies) to protect climate-related financial regulation from being challenged at the World Trade Organization (WTO) or through new and existing trade agreements. • The U.S. Trade Representative should work to remove Investor-State Dispute Settlement (ISDS) provisions from existing U.S. trade agreements and investment treaties to promote environmental protection and sustainable, equitable trade practices.
| tilclimate_hurricanes_educator_guide_full.pdf |
• The United States should use its significant voting power at international financial institutions, such as the WTO, World Bank, and IMF, to shift the focus from the prior emphasis on global economic liberalization to prioritizing a "just transition" and phasing out fossil fuels. It should also support significant restructuring and democratization of these institutions to ensure just attention to Global South concerns.
• Wealthy countries and the large corporations responsible for driving the climate crisis—and benefiting financially and in terms of economic development—should contribute to financing the loss and damage fund operationalized at COP28 to meet all immediate and ongoing needs of climate-vulnerable countries and communities
• Wealthy countries and the large corporations responsible for driving the climate crisis—and benefiting financially and in terms of economic development—should contribute to financing the loss and damage fund operationalized at COP28 to meet all immediate and ongoing needs of climate-vulnerable countries and communities
• The Global South is a term used to describe a diverse group of countries, primarily in the Southern Hemisphere, that share similar experiences of historical colonization, resource extraction, and other forms of exploitation from Global North countries; economic and social challenges; and ongoing efforts toward sustainable development. While countries within this group, including many in Africa, Latin America, Asia, and Oceania, face various obstacles like poverty, limited resources, and inequities, the term focuses on their collective potential and agency rather than solely highlighting their struggles. It's important to remember that the Global South is not a homogenous group, as each country has its unique cultures, histories, and aspirations. The term Global North refers to a collection of countries, predominantly in the Northern Hemisphere, characterized by their historical economic dominance, wealth, and political influence. These countries, including the United States and European nations, often share a legacy of colonialism and extractivism that has played a large role in shaping their current global positions. While economic prosperity and development are often linked with the Global North, it is crucial to recognize the historical power imbalances and persistent inequalities that have resulted from the colonial activities and extractives of these countries
• ESG stands for Environmental, Social, and Governance. It refers to a set of standards, frameworks, and data that investors and organizations consider when evaluating the sustainability and ethical impact of a company's operations on the environment and beyond. Each component of ESG represents a different aspect: • Environmental (E): This relates to a company's impact on the environment. It includes factors such as carbon footprint, energy efficiency, waste management, and adherence to environmental regulations. • Social (S): This considers a company's social impact and relationships with its employees, customers, communities, and other stakeholders. Social factors include labor practices, cost of labor, diversity and inclusion, community engagement, and adherence to human rights. • Governance (G): Governance focuses on the internal policies and structures of a company or organization. This includes corporate governance practices, board composition, executive compensation, transparency, and adherence to ethical business practices. • The distinction between loss and damage and reparations lies in their focus and purpose. While loss and damage refer to the negative impacts and harm caused by climate change, including irreversible losses and the costs incurred, reparations involve compensation or restitution for historical injustices or damages inflicted. While this document will not cover reparations, the case for them is important and must be acknowledged, and some reviewers of this paper noted that achieving a just transition will likely be impossible without decolonization and reparations. Readers are encouraged to learn more about reparations from Global South experts who can speak to how reparations are important to not only climate justice but also to address colonial and other extractive injustices caused over centuries and to this day.
• ESG stands for Environmental, Social, and Governance. It refers to a set of standards, frameworks, and data that investors and organizations consider when evaluating the sustainability and ethical impact of a company's operations on the environment and beyond. Each component of ESG represents a different aspect: • Environmental (E): This relates to a company's impact on the environment. It includes factors such as carbon footprint, energy efficiency, waste management, and adherence to environmental regulations. • Social (S): This considers a company's social impact and relationships with its employees, customers, communities, and other stakeholders. Social factors include labor practices, cost of labor, diversity and inclusion, community engagement, and adherence to human rights. • Governance (G): Governance focuses on the internal policies and structures of a company or organization. This includes corporate governance practices, board composition, executive compensation, transparency, and adherence to ethical business practices. • The distinction between loss and damage and reparations lies in their focus and purpose. While loss and damage refer to the negative impacts and harm caused by climate change, including irreversible losses and the costs incurred, reparations involve compensation or restitution for historical injustices or damages inflicted. While this document will not cover reparations, the case for them is important and must be acknowledged, and some reviewers of this paper noted that achieving a just transition will likely be impossible without decolonization and reparations. Readers are encouraged to learn more about reparations from Global South experts who can speak to how reparations are important to not only climate justice but also to address colonial and other extractive injustices caused over centuries and to this day.
| us-methane-emissions-reduction-action-plan.pdf |
U.S. corporations and the financial institutions that serve them have long profited by extracting natural resources from the Global South with minimal accountability, transparency, and regulation. Many corporations have tried to bolster their reputations in recent decades with inadequate sustainability- and climate-related commitments which often fail to translate to a meaningful shift in strategy to advance a just transition. Additionally, corporations have failed to account for transition risk, and many have fought against disclosure regimes and accounting rules that would reveal their greenwashing. Our ability to ‘unlock private finance’ to meaningfully improve climate investment in the Global South will depend on adequate financial regulation and enforcement mechanisms. In this chapter, we discuss: • Extractive business models of Global North corporations and investors and the lack of accountability • The inadequacy of private financial commitments and initiatives • The problems with carbon credits • Effective net-zero transition planning requires regulation • Enhanced market disclosure and accountability mechanisms • Accounting for remediation and asset retirement provisions for fossil fuel assets • Addressing U.S. financial institutions’ contributions to global systemic risk
Many U.S. corporations and industries are dependent on extractive business models that rely on acquiring natural resources from communities and countries in the Global South and returning profits to shareholders in the North, where their businesses enjoy substantial public subsidies that increase private profits.29 With inadequate transparency around activities, and without robust grievance redress mechanisms,30 human rights abuses and environmental injustices remain inevitable. Nonetheless, there is a growing wave of pressure from governments and investors in demanding transparency regarding these activities, which is aimed at delivering adequate information and compelling corporations and their financiers to bear the costs that are usually shifted onto the host communities in which they operate.
Many corporations claim that their activities have a positive impact on the communities where they operate, while at the same time concealing detrimental negative impacts of their actions in those communities. For example, Shell, a British multinational oil and gas company, has been present in Nigeria since 1937, and claims that Nigeria represents the “largest concentration of social investment spending in the Shell Group.”32 Before Shell’s arrival, the Niger Delta was home to a rich diversity of ecosystems, from lush rainforests and shimmering mangrove forests to sprawling swamplands,33 with farming and fishing central to the local economy of the communities.34 Today, the Niger Delta is recognized as “one of the most polluted places on Earth.”35 According to Nigeria's National Oil Spill Detection and Response Agency, there were 1,156 documented incidents of oil spills in the area in 2023.36 Over decades, regular spills have damaged crop yields and “have led to a decline in the local food production and deepened poverty in communities in the Niger Delta.”37 A 2019 study found that infants born to mothers who lived near spill sites in Nigeria before conception were two times as likely to die as their counterparts before reaching one month of age.
Many U.S. corporations and industries are dependent on extractive business models that rely on acquiring natural resources from communities and countries in the Global South and returning profits to shareholders in the North, where their businesses enjoy substantial public subsidies that increase private profits.29 With inadequate transparency around activities, and without robust grievance redress mechanisms,30 human rights abuses and environmental injustices remain inevitable. Nonetheless, there is a growing wave of pressure from governments and investors in demanding transparency regarding these activities, which is aimed at delivering adequate information and compelling corporations and their financiers to bear the costs that are usually shifted onto the host communities in which they operate.
Many corporations claim that their activities have a positive impact on the communities where they operate, while at the same time concealing detrimental negative impacts of their actions in those communities. For example, Shell, a British multinational oil and gas company, has been present in Nigeria since 1937, and claims that Nigeria represents the “largest concentration of social investment spending in the Shell Group.”32 Before Shell’s arrival, the Niger Delta was home to a rich diversity of ecosystems, from lush rainforests and shimmering mangrove forests to sprawling swamplands,33 with farming and fishing central to the local economy of the communities.34 Today, the Niger Delta is recognized as “one of the most polluted places on Earth.”35 According to Nigeria's National Oil Spill Detection and Response Agency, there were 1,156 documented incidents of oil spills in the area in 2023.36 Over decades, regular spills have damaged crop yields and “have led to a decline in the local food production and deepened poverty in communities in the Niger Delta.”37 A 2019 study found that infants born to mothers who lived near spill sites in Nigeria before conception were two times as likely to die as their counterparts before reaching one month of age.
| tilclimate_wind_and_solar_educator_guide_full.pdf |
Long life Bob, a fisher in the region, shared his story of how an oil spill destroyed his livelihood. Before a major recent oil spill, Bob regularly made 80,000 Nigerian naira (equivalent to USD 108) on a good day selling his catch from the Oluku River, income that he used to support his family for ten years.39 However, a 2023 oil spill contaminated the river and damaged his equipment, leaving him with no means of earning an income.40 In 2008, four farmers, along with the environmental group Friends of the Earth, filed a suit against Shell seeking damages for “lost income from contaminated land and waterways in the region” caused by oil spills that occurred between 2004 and 2007.41 Shell settled the suit by agreeing to pay $15 million to affected communities.42 In 2024, Shell agreed to sell its onshore Nigerian oil and gas subsidiary for $2.4 billion, part of a “broader retreat by western energy companies from Nigeria as they focus on newer, more profitable operations.”43 Researchers at the Centre for Research on Multinational Corporations assert that with this move, Shell is leaving behind “petroleum-contaminated rivers and streams and large areas of polluted land that have devastated the lives and livelihoods of millions of people living in the Niger Delta” and that Shell “has divested to many newly created companies that do not appear to have the funds or willingness” to safely decommission abandoned pipelines.44 In another example, Vale S.A., an international mining company that runs the Onça Puma mine in Brazil, was accused of contaminating the Cateté River with heavy metals, leading to various adverse health and environmental implications for neighboring communities.45 An action against Vale on behalf of the tribes of Kayapó and Xikrin do Cateté resulted in an award of $26.8 million in favor of the tribes for contamination of the Cateté River.46 Additionally, in 2019, a Vale mining dam in Bruma Dinho, Brazil collapsed, resulting in the deaths of more than 270 people, with the majority being Vale employees.47 The company allocated $7 billion to compensate the victims.48 Sixteen people, including Vale executives
| salvagingfamilyvaluables_sept2018.pdf |
Were charged with criminal homicide due to their alleged negligence in ignoring numerous safety complaints regarding the dam, though a court recently suspended the charges against Vale’s former chief executive officer.49 In 2004, Starbucks, a U.S.-based coffee company, launched its first set of ethical sourcing standards called Coffee and Farmer Equity (C.A.F.E.) Practices.50 C.A.F.E. was deployed to assess farms based on economic, social, and environmental standards to encourage transparent, profitable, and sustainable coffee cultivation methods while also safeguarding the welfare of coffee farmers and workers.51 However, in 2018, labor inspectors in Brazil found and rescued 18 workers at a C.A.F.E.-certified coffee farm who were working under terrible conditions—including 11-hour work days, six days a week; rodent infested housing; a lack of drinking water; unhealthy sanitation; and a rigged payment system.”52 In 2024, Starbucks was sued by the National Consumers League for allegedly misleading consumers by claiming that its products have ‘100% ethical’ sourcing despite these documented reports that producers in its supply chain utilized child and forced labor, and had patterns of sexual harassment and assault in their workplaces.53 Another issue of concern is the trending practice in which agricultural investors based in the Global North are buying land in the Global South with little consideration for the environmental and economic impacts on local communities.54 This practice has been called “land grabbing,”55 and it can have significant environmental and social consequences. For instance, an open letter addressed to the prosecutor at the International Criminal Court in the Hague mentioned that land grabs in Cambodia have led to large-scale deforestation and pollution.56 Some U.S.-based financial firms like the Teacher’s Insurance and Annuity Association (TIAA) which claims to aim to “reduce inequalities to achieve a more equitable and sustainable future for all,” are buying farmland in the Global South.57 ActionAid US claims that land deals like these cause “deforestation, violence, forced displacement, and agribusiness operations that use up all the water and pollute the waterways that remain Investors and the public are beginning to recognize the significant risks posed by corporations that exploit the natural resources of marginalized communities and neglect human rights and environmental concerns.59 Efforts by regulators, such as the SEC, to hold corporations accountable for their false reporting and omissions are a step in the right direction. For example, in March 2023, the U.S. Securities and Exchange Commission (SEC) announced that Vale agreed to pay $55.9 million to resolve charges filed in April of the previous year.60 Those charges were related to the company's purportedly false and deceptive disclosures concerning the safety of its dams before the collapse of the Bruma Dinho dam. In its complaint, the SEC had pointed to evidence that the company had been aware that the dam was not in compliance with internationally recognized safety standards, despite Vale's reports reassuring investors that all of its dams were certified as stable.