The SEC continues to use its traditional enforcement mechanisms to address alleged misrepresentations about investment advisers’ claims regarding incorporation of environmental, social and governance (ESG) factors in their investment processes. The agency settled enforcement proceedings against Invesco Advisers, Inc. (Invesco) and WisdomTree Asset Management, Inc. (WisdomTree), both of which allegedly made material misrepresentations regarding their ESG practices. Invesco allegedly overstated the extent of its ESG integration and made inaccurate statements regarding its methodologies. WisdomTree made broad statements regarding exclusionary screening without disclosing the limitations of the datasets it used for such screening and made investments inconsistent with its screening criteria. Additionally, both allegedly failed to adopt appropriate policies and procedures to govern their ESG practices. “At a fundamental level, the federal securities laws enforce a straightforward proposition: Investment advisers must do what they say and say what they do,” said Sanjay Wadhwa, Acting Director of the SEC Division of Enforcement, in the press release announcing the WisdomTree resolution. This article discusses the facts giving rise to the enforcement proceedings and the settlement terms. See “SEC’s Grewal Discusses Enforcement’s Focus on Preventing False and Misleading ESG Claims” (Oct. 24, 2024).