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The GCF's implementation standards for its Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) Policy outline a risk-based framework for managing financial integrity. The standards mandate rigorous counterparty due diligence, annual institutional risk assessments, and the monitoring of financial transactions. They define specific high-risk categories—such as politically exposed persons and shell banks—and prohibit relationships with unregulated money transfer agents or anonymous accounts. The Independent Integrity Unit (IIU) is tasked with overseeing the program, conducting investigations, and managing the reporting of suspicious activities to competent authorities. Additionally, the GCF provides capacity-building support to counterparties to strengthen their own AML/CFT controls.

The Green Climate Fund (GCF) has adopted a policy to protect its resources and reputation from money laundering (ML) and terrorist financing (TF). Aligned with Financial Action Task Force (FATF) recommendations, the policy mandates a risk-based approach to due diligence for all counterparties, including the verification of beneficial owners. It prohibits relationships with entities that fail due diligence, engage in prohibited practices, or are under UN financial sanctions. The Independent Integrity Unit (IIU) is responsible for monitoring implementation, and all GCF personnel must report suspicious activities to the IIU without alerting the parties involved. Records of due diligence and transactions must be kept for at least five years.

The GCF's initial guiding framework for accreditation integrates fiduciary principles and environmental and social safeguards (ESS) into a three-stage process. It distinguishes between basic and specialized fiduciary criteria and utilizes a risk-based approach for environmental and social screening. The process involves a sequence of readiness assessments, institutional reviews, and final legal arrangements, overseen by the GCF Board, Secretariat, and an independent Accreditation Panel.

The Standards for the Implementation of the Anti-Money Laundering and Countering the Financing of Terrorism Policy provide a framework for the Green Climate Fund (GCF) to manage money laundering and terrorist financing (ML/FT) risks. The document mandates a risk-based approach to counterparty due diligence, the establishment of an AML/CFT Program, and the implementation of monitoring and reporting mechanisms for suspicious activities. It defines the roles of the GCF Secretariat, the Independent Integrity Unit (IIU), and the Board in ensuring compliance with international best practices, specifically those set by the Financial Action Task Force (FATF).

The document outlines the Green Climate Fund's (GCF) fiduciary requirements for accredited entities, divided into general fiduciary standards and specialized standards. General standards focus on administrative and financial capacity, including corporate governance, accounting practices (such as IFRS), internal and external auditing, and a robust control framework to prevent fraud and corruption. Specialized standards address project management, monitoring and evaluation, grant-making mechanisms, and the capacity for on-lending or blending financial instruments.

The document provides a comparative analysis of labor policies from the NY State Common Retirement Fund, CalPERS, Maryland SRPS, MassPRIM, and the Illinois State Board of Investment (ISBI). It details how these investors approach the right to organize, compulsory labor, discrimination, wages, layoffs, diversity, health and safety, and working conditions within their private equity portfolios.

The policy brief identifies a gap between the climate commitments of institutional investors and their actual impact on corporate behavior, citing limited transparency and high barriers to shareholder action. It proposes four primary reforms to the Shareholder Rights Directive (SRD) II: introducing a mandatory 'Say on Climate' vote every three years, ensuring legal security for submitting environmental resolutions, increasing transparency requirements for asset owners, managers, and proxy advisors, and lowering the shareholding threshold for submitting resolutions to a maximum of 2% (and 0.2% for large companies).

The document examines the shift toward sustainable investing among US institutional investors, such as foundations and endowments. While financial materiality and policy frameworks like the Paris Agreement are driving interest, significant barriers remain, including short-term biases, misconceptions about fiduciary duty, and a lack of standardized ESG data. The paper outlines five primary sustainable investing strategies and suggests that asset owners begin with internal capacity building and portfolio experimentation to navigate the landscape.