In recognition of World’s Indigenous Peoples Day, Friends of the Earth US has published a new briefing paper called, “Protecting biodiversity from harmful financing: Iconic, transboundary ecosystems.” The briefing paper explains why it is critical for banks and financiers to prohibit direct and indirect financing to harmful activities which negatively impact iconic, transboundary ecosystems. 

Iconic, transboundary ecosystems are regions or habitats treasured for their ecological, aesthetic, and cultural value. They are often transboundary in nature and prominent places for conservation efforts, such as the Amazon and the Arctic. They are also home to Indigenous Peoples and local communities, who are increasingly seen as the best stewards for protecting biodiversity.  

As transboundary ecosystems span across different jurisdictions and management, it is critical that banks and financiers take responsibility to ensure that their financing does not negatively impact ecosystem integrity. In other words, the protection of iconic, transboundary ecosystems demands protecting the entire ecosystem, rather than just pockets or fragments. For instance, iconic ecosystems like the Amazon may soon collapse due to fragmentation caused by deforestation and extractive activities simultaneously occurring across Amazon countries.  

This paper offers key takeaways for banks and financiers on how to protect iconic, transboundary ecosystems and the Indigenous ad local communities who live there. 

Key takeaways of this paper include: 

• Banks and financiers must strengthen protections of iconic, transboundary ecosystems in order to prevent the fragmentation of such areas.  

• The Banks and Biodiversity Initiative recommends that banks and financiers draw on our proposed definition of iconic, transboundary, ecosystems as those “with unique, superlative natural, biodiversity, and/or cultural value which may sprawl across state boundaries, and thus may not be wholly or officially recognized or protected by host countries or international bodies.”  
• Banks and financiers should prohibit harmful financing to iconic, transboundary ecosystems, particularly the Amazon, Arctic, Sundarbans, Coral Triangle and Albertine Rift, amongst others. This requires that due diligence processes account for robust, accurate, assessments which account for ecosystem integrity and ecosystem fragmentation risks.  
• Current and historical bank financing has already led to the fragmentation and devastation of iconic, transboundary, ecosystems critical for climate regulation and biodiversity conservation, including the Amazon, Arctic, Sundarbans, Coral Triangle, and Albertine Rift, amongst others. 
• While some banks have established limited protections on the Amazon and Arctic, particularly among commercial banks, the international banking sector writ large should develop explicit and strong policies to protect iconic, transboundary, ecosystems.  
• Banks should reference and assess multiple sources in decision making around investments in iconic areas. In particular different approaches to Arctic mapping are important and banks should be aware to assess various sources when assessing the risks of a particular proposed project or activity there.  

• Establishing exclusionary policies for iconic, transboundary, ecosystems can be an effective way for banks and financiers to harmonize institutional climate and biodiversity targets by protecting the key ecosystems with high climate regulatory and biodiversity values simultaneously.  
• Indigenous Peoples and local communities play a critical role in protecting climate regulatory and high biodiversity ecosystems.  
• Banks and financiers should improve or establish strong Indigenous Peoples policies which protect the rights to self-determination and sovereignty.  
• Banks and financiers should require free, prior, informed consent as a right to Indigenous Peoples, and as a best practice for consulting local communities. 

This paper is part of Friends of the Earth US’ new Protecting Biodiversity from Harmful Financing briefing paper series, which underscores why banks and financiers should exclude harmful, unsustainable financing to activities and projects which impact critical, at-risk ecosystems.  

Each briefing paper is dedicated to a key area as identified by the Banks and Biodiversity Initiative’s eight proposed No Go Areas. This paper is o iconic, transboundary ecosystems, which is paper 08 of the series. 

Full briefing paper series includes: 

• No Go area 1: Internationally recognized areas 
• No Go area 2: Nationally recognized areas 

• No Go area 3: Key Biodiversity Areas and habitats with endangered and endemic species 
• No Go area 4: Primary and vulnerable secondary forests  
• No Go area 5: Free flowing rivers 
• No Go area 6: Protected or at-risk marine and coastland ecosystems   
• No Go area 7: Areas where Free, Prior and Informed Consent has not been obtained by Indigenous Peoples and local communities  

• No Go area 8: Iconic, transboundary ecosystems 

Friends of the Earth US is part of the Banks and Biodiversity Initiative, a civil society coalition which advocates that banks and financiers strengthen their biodiversity policies and practices in order to halt and reverse biodiversity loss. Learn more at banksandbiodiversity.org.   

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In recognition of World’s Indigenous Peoples Day, a new briefing paper calls on banks and financiers to prohibit harmful financing in areas where Free, Prior, and Informed Consent (FPIC) has not been obtained from Indigenous Peoples and local communities. 

Co-published by Friends of the Earth US, Cultural Survival, and Instituto Maíra, the paper, “Protecting biodiversity from harmful financing: Areas where the free, prior, informed consent (FPIC) of Indigenous and Local Communities have not been obtained,” demonstrates the vital role of Indigenous Peoples and local communities play in protecting biodiversity. It explains the nuances in how Free, Prior, Informed Consent is a unique right to Indigenous Peoples guaranteed under international law, whereas FPIC can be used as a best practice in engaging local communities.  

Although Indigenous Peoples make up just six percent of the world’s population, their lands hold 80% of the world’s biodiversity. In order to protect biodiversity, banks and financiers must protect the rights of Indigenous Peoples and local communities, as the two are inexorably linked. Indigenous and community lands and forests are associated with lower rates of deforestation, higher levels of carbon storage, reduced conflict, and overall better biodiversity conservation. Yet banks are driving biodiversity loss, climate change, and human rights abuses via their continued financial support to high-risk sectors, particularly fossil fuels, extractive industries, and industrial agriculture.  

The paper provides useful lessons and key takeaways on how the international banking sector can establish robust Indigenous Peoples policies.  

Key takeaways of this paper include: 

• Indigenous Peoples are the best guardians of world’s biodiversity, in which to protect Indigenous rights is to protect biodiversity. 
• FPIC is defined as consent that is given freely, by people fully informed of the consequences, prior to any decision being made, and according to their own decision-making processes.  
• FPIC is enshrined under international human rights law for Indigenous Peoples, and is a process for expressing the right of Indigenous Peoples to self-determination.  
• FPIC can be used as a best practice for meaningfully engaging with local communities.  
• Respecting Indigenous Peoples’ right to FPIC is critical in allowing and enabling them to exercise their right to self-determination, and their ability to determine their own economic, social, and cultural development paths.  

• Failing to implement FPIC correctly often leads to even more risks and challenges for both banks and their clients.  
• Banks and financiers must establish a robust Indigenous Peoples Policy which requires FPIC, if not already developed  
• Banks and financiers should ensure that Indigenous Peoples and biodiversity policies or frameworks are complementary and mutually reinforcing.  
• Banks and financiers should prohibit financing to sectors and companies which are well known drivers of human and environmental rights violations, such as the fossil fuel and industrial agribusiness sectors.  
• Banks and financiers should establish institutional accountability mechanisms, if not already developed. They should also require any project level grievance mechanism to be fair, accessible, and effective.  

• Banks, financiers, and clients should plan for a “no project” option at any stage of a financed activity in order to allow and facilitate proper implementation of FPIC as an iterative process.  
• Banks and financiers should consider the historical, documented patterns of past abuse against Indigenous Peoples in high-risk sectors, and account for how Indigenous communities have responded to previous or similar projects in nearby regions.  
• Where Indigenous Peoples have clearly and repeatedly spoken out against certain sectors and relevant projects in the past, banks should respect Indigenous Peoples’ choice not to engage in any further or future proposed activities or projects.  
• Banks and financiers should explicitly reference and comply with the UN Guiding Principles on Business and Human Rights, in addition to key international law standards on human rights, and Indigenous customary law and protocols.  
• Banks and financiers should publicly disclose lending, underwriting, shareholding, and investment in high-risk sectors, including information on ownership and shareholder interests in specific investments in oil palm and other agribusiness companies to ensure transparency, including interests in shadow companies registered in offshore jurisdictions.  

• Banks and financiers should establish meaningful incentives for staff and clients to instill and encourage a culture of careful due diligence and responsible decision making on human rights and environmental governance.  
• Banks and financiers should include non-compliance clauses in financing agreements, such as the right to interrupt or cancel financing where there is evidence of violation of land rights, FPIC, and/or serious unresolved community grievances (i.e. killings, violence, retaliation, threats, etc.) 

This paper is part of Friends of the Earth US’ new “Protecting Biodiversity from Harmful Financing” briefing paper series, which underscores why banks and financiers should exclude harmful, unsustainable financing to activities and projects which impact critical, at-risk ecosystems.  

Each briefing paper is dedicated to a key area as identified by the Banks and Biodiversity Initiative’s eight proposed No Go Areas. This paper is about areas where free, prior and informed consent has not been obtained by Indigenous Peoples and local communities, which is paper 07 of the series. 

Full briefing paper series includes: 

• No Go area 1: Internationally recognized areas 
• No Go area 2: Nationally recognized areas 
• No Go area 3: Key Biodiversity Areas and habitats with endangered and endemic species 
• No Go area 4: Primary and vulnerable secondary forests  

• No Go area 5: Free flowing rivers 
• No Go area 6: Protected or at-risk marine and coastland ecosystems   
• No Go area 7: Areas where Free, Prior and Informed Consent has not been obtained by Indigenous Peoples and local communities  
• No Go area 8: Iconic, transboundary ecosystems 

Friends of the Earth US is part of the Banks and Biodiversity Initiative, a civil society coalition which advocates that banks and financiers strengthen their biodiversity policies and practices in order to halt and reverse biodiversity loss. Learn more at banksandbiodiversity.org.   

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Friends of the Earth US and the Deep Sea Mining Campaign have co-published a new briefing paper, “Protecting biodiversity from harmful financing: Protected or at-risk marine or coastland ecosystems.” In recognition of World’s Indigenous Peoples Day, the briefing paper explains why it is crucial for banks and financiers to prohibit direct and indirect financing to harmful activities which negatively impact marine and coastland ecosystems and the Indigenous and local communities that depend on them. 

Marine and coastland areas are crucial for sustaining biodiversity, regulating the climate, and preserving Indigenous and community livelihoods, sustaining a multitude of resources and cultural significance to Indigenous Peoples and local communities worldwide.  

However, harmful bank financed activities are threatening protected and at-risk marine and coastland ecosystems. This includes ongoing financial support to the fossil fuel industry, mining, and illegal fishing, as well as emerging new threats, such as deep sea mining and tailings disposal.  

The paper offers key takeaways on how the international banking sector can strengthen policies in order to fully protect at-risk and protected marine and coastland ecosystems and respect the rights of Indigenous Peoples and local communities. 

Key takeaways of this paper include:   

• Banks and financiers should strengthen protections for protected or at-risk marine or coastland ecosystems and prohibit harmful financing impacting these areas. The Banks and Biodiversity Initiative encourages banks and financiers to draw from our proposed definition of such ecosystems: “protected or at-risk marine or coastland ecosystems, include mangrove forests, wetlands, reef systems, and those located in formally, informally, or traditionally held areas, Indigenous Territories (ITs), or public lands not yet demarcated, or Indigenous and Community Conserved Areas (ICCA).”  
• The international banking sector writ large has yet to fully develop protections on marine and coastland areas.  

• Banks and financiers should draw from existing international frameworks in order to identify, prioritize, and protect protected and at-risk marine and coastland areas.  
• Banks and financiers should take a precautionary approach to deep sea mining, and establish a moratorium on financing deep sea mining unless the risks of mining are comprehensively understood and effective protection can be ensured, and that mechanisms are in place to consult with the public throughout decision-making.  
• Banks and financiers should prohibit financing to the expansion, extraction, and shipping of fossil fuels. 
• Banks and financiers should conduct stronger due diligence for land-based activities which may have significant marine and coastland impacts, and require relevant, accurate, robust assessments on such impacts. These include associated infrastructure and indirect impacts of fossil fuel, mining, and other similar extractive activities in coastal areas, such as ports, shipping traffic, pollution, noise pollution, etc.  
• Banks and financiers should consider how their financing decisions may preclude financing in more sustainable development pathways. For instance, financing harmful, high-risk sectors, such as fossil fuels, often precludes financing sustainable alternatives, especially in coastal areas with high tourism potential or biodiversity value.  

• Banks and financiers would benefit from improving or establishing strong Indigenous Peoples policies which protect the right to self-determination, sovereignty, and free, prior, informed consent.  
• Banks and financiers should require free, prior, informed consent as a right to Indigenous Peoples, and as a best practice for consulting local communities.  
• Projects and activities that harm biodiversity and Indigenous communities face potential legal and financial liabilities, making them risky investments for banks. 

This paper is part of Friends of the Earth US’ new “Protecting Biodiversity from Harmful Financing” briefing paper series, which underscores why banks and financiers should exclude harmful, unsustainable financing to activities and projects which impact critical, at-risk ecosystems.  

Each briefing paper is dedicated to a key area as identified by the Banks and Biodiversity Initiative’s eight proposed No Go Areas. This paper is about protected or at-risk marine and coastland ecosystems, which is paper 06 of the series. 

Full briefing paper series include: 

• No Go area 1: Internationally recognized areas 
• No Go area 2: Nationally recognized areas 
• No Go area 3: Key Biodiversity Areas and habitats with endangered and endemic species 

• No Go area 4: Primary and vulnerable secondary forests  
• No Go area 5: Free flowing rivers 
• No Go area 6: Protected or at-risk marine and coastland ecosystems   
• No Go area 7: Areas where Free, Prior and Informed Consent has not been obtained by Indigenous Peoples and local communities  
• No Go area 8: Iconic, transboundary ecosystems 

Friends of the Earth US is part of the Banks and Biodiversity Initiative, a civil society coalition which advocates that banks and financiers strengthen their biodiversity policies and practices in order to halt and reverse biodiversity loss. Learn more at banksandbiodiversity.org.   

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Six months since its adoption, banks and financiers have yet to develop concrete plans to implement the Kunming-Montreal Global Biodiversity Framework (GBF). On June 26, 2023, 74 civil society organizations endorsed a briefing which urgently calls on banks and financiers to take responsibility for their role in driving the biodiversity crisis by endorsing a new briefing, “How Should Financiers Align with the Global Biodiversity Framework? Five Key Principles”.  

Developed by Bank Information Center, BankTrack, Rainforest Action Network, and Friends of the Earth US, the briefing recommends five key principles banks and financiers must implement in order to stop and reverse biodiversity loss effectively and equitably. These include:  

1. Halting and reversing biodiversity loss 
2. Respecting and prioritizing the rights of Indigenous Peoples and local communities 
3. Fostering a Just Transition 
4. Ensuring ecosystem integrity 
5. Aligning institutional objectives across sectors, issues, and instruments 

The GBF aims to reverse the currently unprecedented rates of biodiversity loss through a “whole-of-society approach,” explicitly including public and private financiers. Financiers are expected to align their “financial flows” with the goals and targets of the GBF in order to actively stop biodiversity loss, restore ecosystems, and protect Indigenous Peoples’ rights, which are crucial for protecting the world’s remaining biodiversity.  

The financial sector has long supported activities and sectors that are driving nature destruction and violating human rights. As upstream, enabling actors, public and private financial institutions play a critical role in accelerating, slowing, or preventing key drivers of biodiversity loss.  

Read what financiers must do to ensure they stop enabling harm to nature and people in the full briefing here. 

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Terrance Bankston, Senior Ports and Freights Campaigner at Friends of the Earth and Environmental Justice Activist based in Newark, issued the following statement: 

Polluters who want a permission slip to perpetuate environmental inequalities and inequity must be checked at the door. It’s not surprising that New Jersey’s Environmental Justice Rule faces legal challenges by those who are most inconvenienced by it – that is, groups representing industries that want to expand facilities while poisoning our most disadvantaged communities. We will continue to advocate for this crucial legislation and ensure that permitting has strict regulations that protect our New Jersey communities from pollution and political bullying. 

Communications Contact: Erika Seiber, eseiber@foe.org

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The paper offers useful lessons and key takeaways on how the international banking sector can establish strong water and exclusionary policies in order to protect free flowing rivers and the communities reliant on them. Free flowing rivers are critical for safeguarding biodiversity, maintaining water supply, mitigating climate change, and supporting local and Indigenous communities. However, free flowing rivers are threatened by harmful dams and water infrastructure activities, which are often enabled by bank financing. 

This paper is part of Friends of the Earth US’ new Protecting Biodiversity from Harmful Financing briefing paper series, which underscores why banks and financiers should exclude harmful, unsustainable financing to activities and projects which negatively impact critical, at-risk ecosystems. Each briefing paper is dedicated to a key area as identified by the Banks and Biodiversity Initiative’s eight proposed No Go areas. Free flowing rivers are considered as No Go Area 5, which is Paper 05 of the series. Briefing papers focusing on No Go Areas 6-8 are forthcoming.   

Key takeaways of this paper include:  

• The Banks and Biodiversity Initiative defines free flowing rivers as rivers that flow undisturbed from their source to mouth, at either the coast, an inland sea or at the confluence with a larger river, without encountering any dams, weirs or barrages and without being hemmed in by dykes or levees 
• Fluvial connectivity and hydrological alterations are key aspects when assessing the free flow of a river 
• Banks and financiers should prohibit financing which negatively impacts the connectivity and flow of free flowing rivers, in order to preserve the livelihoods, biodiversity, and multiple other benefits of the world’s remaining free flowing rivers 
• Freshwater river ecosystems are disappearing three times faster than forests 

• A major driver of biodiversity and habitat loss in freshwater ecosystems is river fragmentation caused by dam building 
• Harmful water and dam projects financed by banks are historically associated with high risks of negative reputational, environmental, social, and biodiversity impacts 
• Banks and financiers should require free, prior, informed consent of impacted local and Indigenous communities across all transactions as a means to reduce the high risks associated with harmful water and dam projects 
• Banks and financiers should support a moratorium on new dams in the economic recovery as a key step in reassessing energy options and plans, including all pipeline projects, and reducing the probability of increasing debt burdens from high-cost, high-risk/low reward projects  
• Banks and financiers can facilitate opportunities to protect threatened biodiversity and freshwater ecosystems (and the communities and economies that rely on them) by moving energy production away from rivers 

• Banks and financiers should prioritize upgrades to existing hydropower projects to increase efficiency instead of building new dams. This can include retrofitting turbines, improved pumped storage, protecting upstream forests and watersheds to reduce siltation, and grid-integration with wind, solar, and other energy innovations 
• Banks and financiers should require clients to assess potential impacts of water related infrastructure and to conduct robust, thorough basin wide assessments which incorporate river pressure indicators and other criteria discussed in the Banks and Biodiversity Briefing Paper Series, “Protecting Biodiversity from Harmful Financing: No Go Areas for the International Banking Sector” 
• Protecting rivers protects communities, and communities protect rivers  

Friends of the Earth US is part of the Banks and Biodiversity Initiative, a civil society coalition which advocates that banks and financiers strengthen their biodiversity policies and practices in order to halt and reverse biodiversity loss. Learn more at Banksandbiodiversity.org.  

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The paper, called “Protecting biodiversity from harmful financing: Intact primary and vulnerable secondary forests,” details how banks and financiers are driving forest degradation and deforestation by financing sectors tied to high forest risks. The paper urges banks and financiers to stop financing deforestation and forest degradation by developing robust forest policies which also protect forest dwelling local and Indigenous communities.  

In advocating why primary and vulnerable secondary forests must be protected, the paper discusses the irreplaceable values that forests possess in curbing climate change, preserving biodiversity, sustaining ecosystem functions, and supporting Indigenous and local communities’ livelihoods. The paper offers an inclusive definition of forests which banks should draw from, particularly in light of the controversies and complexities associated with international and national definitions of forests.  

This paper is part of Friends of the Earth US’ Protecting Biodiversity from Harmful Financing briefing paper series, which underscores why banks and financiers should exclude harmful, unsustainable financing to activities and projects which negatively impact critical, at-risk ecosystems. Each briefing paper is dedicated to a key area as identified by the Banks and Biodiversity Initiative’s eight proposed No Go areas. Intact primary and vulnerable secondary forests are considered as No Go Area 4, which is Paper 04 of the series. Briefing papers focusing on No Go Areas 6-8 are forthcoming.   

Key takeaways of this paper include:  

• Banks and financiers are driving global deforestation and forest degradation by supporting high forest risk sectors  
• Deforestation occurs in both primary and vulnerable secondary forests – banks and financiers should prohibit financing which causes, enables, or accelerates deforestation and forest degradation 
• Key sectors driving global deforestation and forest degradation include but are not limited to palm oil, pulp and paper, beef, soy, logging, biomass, and rubber 

• Banks and financiers should exclude financing to clients and sectors which may negatively impact intact primary, natural forests and vulnerable secondary forests 
• A primary forest is a natural forest that is the result of biological and evolutionary processes and that has not been degraded by significant industrial, human driven activities. A key characteristic of primary, natural forests is that mature trees dominate the canopy and contains most or all of its native plant and animal species. Primary, natural forests include all successional age classes (young to old-growth) having no industrial human activities, including primary forests regenerating after wildfire. Primary, natural forests covers a range of related terms including “old growth forest”, “ancient forest”, “primeval forest”, “mature forests”, and “intact forest landscapes”  
• Given the range of regeneration rates among different forest types, the exact age of a primary forest is less relevant than whether its natural, ecological processes have reached its climax. This detail is particularly important in cases where even if a forest has been previously disturbed or logged, if the forest still predominantly functions and retains the key characteristics of a forest at its climax, it should still be considered a primary, natural forest and be protected 
• Vulnerable, secondary forests are forests which are regenerating largely through natural processes after significant human and/or natural disturbance of the original forest vegetation at a single point in time or over an extended period. In protecting the ability of secondary forests to recover and regrow, secondary forests should be considered as vulnerable when at risk of further degradation or destruction by planned or future harmful activities 
• Defining forests can be challenging as different forest definitions reflect different forest management objectives and interests 

• Banks and financiers should be aware of the complex dynamics of various forest management objectives and interests, and not over-rely on narrow forest definitions and assessments of third party or industry assessors in conducting their own due diligence    
• Banks and financiers must be aware of the controversial legacy of forest definitions across international, regional, and local contexts, and develop forestry policies which are rooted in the basic, overarching aim to stop deforestation and protect forest dwelling local and Indigenous communities  
• Banks and financiers should coordinate and complement institutional forestry policies holistically with other thematically crosscutting policies on climate, biodiversity, and Indigenous Peoples 
• Managing both primary and vulnerable secondary forests sustainably and equitably is critical for meeting other interdependent objectives, including safeguarding community rights, solving climate change, and halting biodiversity loss.  
• Banks and financiers should adopt no deforestation policies, and establish policies which favor proforestation, which is the concept of allowing and enabling continuous forest growth that is uninterrupted by active management or timber harvesting 

• Banks and financiers should embed the principles of free, prior, informed consent in their forestry policies 

Friends of the Earth US is part of the Banks and Biodiversity Initiative, a civil society coalition which advocates that banks and financiers strengthen their biodiversity policies and practices in order to halt and reverse biodiversity loss. Learn more at Banksandbiodiversity.org.  

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As the chair of this year’s CBD COP, Chinese authorities should showcase their commitment to protecting biodiversity by holding Chinese banks and companies accountable for their harmful, overseas impacts, and encourage Chinese actors to meaningfully engage and address community concerns. 

The civil society letter highlights China’s commitments to protecting biodiversity, and provides concrete recommendations for how Chinese authorities and overseas actors can do their part in stopping and reversing the biodiversity crisis. The letter also includes a list of 37 controversial projects associated with harmful biodiversity, environmental, and social impacts which Chinese banks and companies are currently supporting, and notes compelling examples where Chinese banks and companies have withdrawn support from activities with harmful biodiversity impacts in the past. Although these cases represent the exception rather than norm, they indicate the capability of Chinese actors to take positive steps in protecting biodiversity.  

As the Belt and Road Initiative expands, Chinese banks and companies will likely continue to have significant environmental, social, and biodiversity impacts. In order to adequately address such impacts, Chinese banks and companies must improve institutional mechanisms for engaging with the public and impacted communities, as well as build trust and credibility amongst the international and local communities that they are willing and capable in identifying and addressing biodiversity risks posed by their overseas activities.  

Read the letter in English and Chinese. 

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This paper is part of Friends of the Earth US’ new Protecting Biodiversity from Harmful Financing briefing paper series, which underscores why banks and financiers should exclude harmful, unsustainable financing to activities and projects which impact critical, at-risk ecosystems. Each briefing paper is dedicated to a key area as identified by the Banks and Biodiversity Initiative’s eight proposed No Go Areas. Key Biodiversity Areas and habitats with threatened and endemic species are considered as No Go Area 3, which is Paper 03 of the series. Briefing papers focusing on No Go Areas 4-8 are forthcoming.  

Key takeaways of this report include: 

• Banks and financiers should establish an institutional objective to actively halt and reverse biodiversity loss, while simultaneously aspiring to restore ecosystem functions. 
• Biodiversity is a critical contributor and indicator of the health of ecosystem functions. 
• Banks and financiers are exposed to material risks of biodiversity loss in two ways – firstly, in terms of directly driving or exacerbating negative biodiversity impacts caused by specific financed activities; and secondly, in terms of how such financed activities may in turn contribute to and drive the broader, systemic biodiversity loss (such as land use change, pollution, climate change, and over-exploitation of natural resources), which in turn impacts the long-term sustainability of sectors or areas where a financier may invest in. 
• An effective, immediate approach to minimizing a bank’s impact on biodiversity loss is to prohibit financing in areas with Near Threatened, Vulnerable, Endangered, Critically Endangered, and endemic species, in addition to Key Biodiversity Areas. 
• Bank and financier definitions of Critical Habitat should include habitats of Near Threatened, Vulnerable, Endangered, Critically Endangered, and endemic species, in addition to KBA 

• Offsets as a mitigation measure are ineffective in managing biodiversity risks. 
• The use of biodiversity tools and datasets are an important starting point when undertaking environmental and biodiversity assessments, but their use should not be seen as a proxy or an end point in due diligence processes. 
• Depending if most or all of a non-threatened species’ population occurs at a particular site (especially for range restricted species), a species could become highly threatened by a bank’s decision to finance activities in an area. 
• It is important for banks to not only consider species which are currently threatened, but to also consider how proposed bank financed activities can tip the scale in potentially causing species to become threatened. 
• Vested or conflicts of interests commonly result in inadequate or invalid EIA documents. 

• Banks and financiers should establish specialized staff or processes to interrogate and validate Environmental Impact Assessment (EIA) findings, and disclose EIAs and relevant documents publicly in order to encourage independent verification of such assessments. 

Friends of the Earth US is part of the Banks and Biodiversity Initiative, a civil society coalition which advocates that banks and financiers strengthen their biodiversity policies and practices in order to halt and reverse biodiversity loss. Learn more at Banksandbiodiversity.org. 

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This paper is part of Friends of the Earth US’ new Protecting Biodiversity from Harmful Financing briefing paper series, which underscores why banks and financiers should exclude harmful, unsustainable financing to activities and projects which impact critical, at-risk ecosystems. Each briefing paper is dedicated to a key area as identified by the Banks and Biodiversity Initiative’s eight proposed No Go Areas. Nationally and Sub-nationally recognized areas are considered as No Go Area 2, which is Paper 02 of the series. Briefing papers focusing on No Go Areas 4-8 are forthcoming.  

Key takeaways of the report include: 

• Banks and financiers should prohibit financing to harmful, industrial, extractive activities which negatively impact nationally recognized areas. 
• The obtainment of permits and licenses should not be used as a proxy for legal compliance. 
• Banks and financiers should strengthen due diligence processes to validate the legitimacy of required permits or licenses. 

• Assessing a client’s environmental and human rights record should be an important criterion in screening out low quality, high risk clients. 
• Banks and financiers should consider blacklisting companies with a recurring record of poor environmental and social performance. 
• Financing harmful, high risk sectors, such as fossil fuels, preempts alternatives for financing sustainable development. 
• The creation of conservation areas as a financing condition bears a poor record in delivering actual biodiversity conservation results, as host country governments may renege on such commitments. 
• Many nationally recognized areas overlap with Indigenous lands and community conserved areas, and so it is vital that banks understand the historic and current ties that Indigenous and local communities may have to an area. 

• Banks and financiers would benefit from improving or establishing strong Indigenous Peoples policies which protect the right to self-determination, sovereignty, and free, prior, informed consent. 

Friends of the Earth US is part of the Banks and Biodiversity Initiative, a civil society coalition which advocates that banks and financiers strengthen their biodiversity policies and practices in order to halt and reverse biodiversity loss. Learn more at Banksandbiodiversity.org. 

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