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SEC Imposes $17.5 Million Fine Against Investment Adviser for Greenwashing

3 On November 8, the SEC and an investment advisor entered into a settlement to resolve an administrative proceeding featuring allegations of greenwashing. Specifically, the investment advisor was alleged to have made...more

Energy & Sustainability Litigation Updates — November 2024

Despite the recent disbandment of the SEC’s Climate & ESG Task Force, the SEC is continuing to pursue enforcement actions concerning environmental issues, including greenwashing. Notably, over the past several weeks, the SEC...more

Energy & Sustainability Litigation Updates — October 2024

The Securities & Exchange Commission has disbanded its Climate & ESG Task Force, which had been launched with great fanfare in March 2021 at the beginning of the Biden administration. However, the Climate & ESG Task Force had...more

Minnesota Federal Court Says Greenwashing Claims Concerning Consumer Products Can Proceed

On September 25, 2024, the federal district court in Minnesota denied Target Corp.'s motion to dismiss a consumer-fraud action against it featuring claims that a class of consumers were “deliberately misled [] by [Target]...more

Recent Greenwashing Litigation Focuses on Consumer Products

Over the past couple of weeks, there have been a pair of greenwashing lawsuits filed--by both private plaintiffs and government regulators--that highlight the current focus on consumer products as a centerpiece of...more

EU Regulators Announce Greenwashing Investigation of 20 Airlines

The European Commission and EU consumer authorities have sent letters to 20 airlines “identifying several types of potentially misleading green claims,” focusing on “claims made by airlines that the CO2 emissions caused by a...more

Significant ESG Enforcement Action by the SEC Against Major Investment Advisor

On September 25, 2023, the SEC announced a settled administrative proceeding against a major investment advisor in which it agreed to pay a $19 million civil penalty for, effectively, greenwashing activities--i.e., pretending...more

CFTC Holds Second Voluntary Carbon Markets Convening

Yesterday, on July 19, 2023, the CFTC held its second voluntary carbon markets convening, approximately a year following the initial voluntary carbon markets convening on June 2, 2022. The stated purpose of the meeting is...more

CFTC Asserts Enforcement Authority Over Carbon Markets

Last week, the CFTC solicited whistleblowers in connection with "potential [] fraud and manipulation" in "voluntary carbon markets," particularly in circumstances "in which high-quality carbon credits, also known as carbon...more

Energy & Sustainability Litigation Updates — August 2022

In June 2022, the Supreme Court issued its decision in West Virginia v. EPA, which held that, under the “major questions doctrine,” the EPA lacked the authority under the Clean Air Act to devise emissions caps based on the...more

A Diffuse Mission for the SEC's Climate and ESG Task Force?

On July 20, 2022 the SEC issued a press release concerning the resolution of an administrative proceeding in which the defendants "violated certain antifraud and reporting provisions of the federal securities laws and []...more

SEC Climate and ESG Task Force Issues First Enforcement Action

The SEC's Climate and ESG Task Force has now issued its first enforcement action. The SEC has brought a 76-page complaint in federal district court against Vale, S.A., a Brazilian mining company, alleging that Vale "ma[de]...more

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