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California States It Will Exercise "Enforcement Discretion" for First Year of Climate Disclosures If Companies Act in Good Faith

2 On December 5, 2024, the California Air Resources Board--the agency responsible for implementing California's climate disclosure regulations--announced that it would “exercise enforcement discretion for the first reporting...more

SEC Issues Risk Alert About Greenwashing and ESG Disclosures

1 On November 4, the SEC's Division of Examinations issued a risk alert that identified systematic problems with funds' ESG disclosures. Specifically, the SEC stated that “[f]unds [] mischaracterized the use of...more

Alleged Carbon Markets Fraud Leads to Criminal Charges

1 The U.S. Attorney's Office for the Southern District of New York recently launched a criminal prosecution in connection with “a scheme to commit fraud in the carbon markets,” specifically that a company and its executives...more

SEC Disbands ESG Task Force

It has been reported that the Securities & Exchange Commission has disbanded its Climate & ESG Task Force. This same task force had been launched with great fanfare in March 2021, at the beginning of the Biden...more

Canada Increases Enforcement Focus on Greenwashing

As of June 2024, Canada added certain provisions to its Competition Act that explicitly target the practice of greenwashing. In particular, according to the Canadian Competition Bureau, these amendments: (1) “requir[e] that...more

SEC Argues That Climate Disclosure Regulation Survives Demise of the Chevron Doctrine

Earlier this year, the SEC issued its long-awaited regulation concerning mandatory climate disclosures.  As expected, this climate disclosure rule was immediately challenged in the courts by, among others, conservative states...more

Oklahoma Judge Temporarily Blocks Law Penalizing Companies Engaged in Fossil Fuel Boycott

Earlier this week, a state court judge in Oklahoma issued a temporary restraining order that blocks--for now--enforcement of an Oklahoma law that deprives companies deemed to boycott the fossil fuel industry of the ability to...more

Energy & Sustainability Litigation Updates - January 2023

Climate Change Litigation: Beginning in 2017, an array of state and local governments began pursuing claims against major fossil fuel producers — particularly the major oil companies (Chevron, Exxon, BP, Shell, and...more

Energy & Sustainability Litigation Updates — December 2022

SEC Enforcement: In its yearly summary of enforcement activity, the SEC chose to highlight ESG-related issues as one of only a handful of subject matter areas that the SEC is focused on, indicating the significant priority...more

SEC Highlights ESG Enforcement Activity in Annual Report

The SEC recently announced its yearly summary of enforcement activity. Among the items it chose to highlight were its efforts to enforce ESG-related issues. ESG was one of only a handful of subject matter areas that the SEC...more

SEC Announces Disclosures and Rules Changes Intended to Combat "Greenwashing"

Today, the SEC issued two complementary press releases announcing certain proposed rules. First, the SEC announced "proposed amendments to enhance and modernize the Investment Company Act 'Names Rule'" that would "extend the...more

Reports of SEC Enforcement Activity Concerning ESG Disclosures

It has been publicly reported that the Dallas office of the SEC is currently engaged in an investigation of ESG disclosures by companies doing business with state government entities in Texas. Specifically, the SEC is...more

Commissioner Crenshaw Highlights SEC Focus on Climate Issues

Last week, during a program on "Building the Financial System of the 21st Century," in the course of a speech principally focused on various market risks, SEC Commissioner Crenshaw nonetheless availed herself of the...more

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