Litigation Risks Posed by “Greenwashing” Claims for ESG Funds

Gunnar Larson g at xny.io
Tue Apr 26 04:15:02 PDT 2022


New article yesterday from Harvard:
https://corpgov.law.harvard.edu/2022/04/25/litigation-risks-posed-by-greenwashing-claims-for-esg-funds/?utm_content=bufferf68c0&utm_medium=social&utm_source=linkedin.com&utm_campaign=buffer
-------
Litigation Risks Posed by “Greenwashing” Claims for ESG Funds
Introduction

The massive flow of assets into ESG-focused funds reflects the intense and
growing demand for investment products that enable investors to put their
values into action while pursuing strong financial returns in their
portfolios. The dramatic growth of the ESG funds sector has predictably
attracted the attention of regulators, commentators and the private
plaintiffs’ bar. The SEC’s Division of Enforcement last year formed a
Climate and ESG Task Force <https://www.sec.gov/news/press-release/2021-42> to,
among other things, “analyze disclosure and compliance issues relating to
investment advisers’ and funds’ ESG strategies” and ESG related issues have
moved to the forefront of exams conducted of registered investment
advisers. States have similarly demonstrated an increased focus on ESG
regulations: a dozen state attorneys general, including those of California
and New York, sent a letter to the SEC
<https://www.law360.com/articles/1401457/an-early-look-at-what-state-ags-want-from-esg-disclosures>
last
year that called for increased ESG-related disclosures for climate-related
financial risks by “all SEC-regulated firms.” Notably, foreign regulators
have been ahead of their U.S. counterparts in focusing on ESG disclosures;
in particular, the Sustainable Finance Disclosure Regulation (SFDR) in the
European Union
<https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32019R2088> will
require disclosure of ESG considerations by all funds. The head of the
SEC’s Climate and ESG Task Force has emphasized
<https://www.law360.com/articles/1373422/sec-s-esg-unit-chief-says-existing-regs-key-to-enforcement>
that
its review of ESG fund disclosures and marketing materials will be guided
by “long-standing principles of materiality and disclosure” in assessing
potential violations of the securities laws or advisers’ fiduciary duties.

The growing ESG fund sector has also been the subject of recent public
criticism from various quarters, particularly claims of greenwashing
leveled against climate-focused funds, from media outlets including Time
<https://time.com/6095472/green-esg-investment-funds-greenwashing/>, USA
Today
<https://www.usatoday.com/story/opinion/2021/03/16/wall-street-esg-sustainable-investing-greenwashing-column/6948923002/>
, The Economist
<https://www.economist.com/leaders/2021/05/22/sustainable-finance-is-rife-with-greenwash-time-for-more-disclosure>
, Reclaim Finance
<https://reclaimfinance.org/site/en/our-fights/green-bonds-watch-out-it-could-be-a-trap>,
and Responsible Investor
<https://www.responsible-investor.com/articles/can-we-rely-on-shareholders-to-compel-corporations-to-meaningfully-act-on-esg-issues>.
According to the sponsors of a number of published studies, like As You Sow
<https://www.asyousow.org/press-releases/2022/1/11/lack-of-truth-in-labeling-esg-mutual-funds-etfs>
, InfluenceMap
<https://influencemap.org/report/Climate-Funds-Are-They-Paris-Aligned-3eb83347267949847084306dae01c7b0>,
and Morningstar
<https://www.morningstar.com/en-uk/lp/sfdr-article8-article9?utm_medium=native&utm_campaign=emea_investors_sites>,
many funds with a sustainable or “green” investment thesis are not living
up to their names and promises, because their portfolio holdings are not
sufficiently aligned with specified standards for addressing climate
change. Indeed, SEC Chair Gary Gensler published a video on March 1, 2022
in which he expressed skepticism about whether many ESG-focused funds live
up to their names, asserting that the investing public does not have
sufficient information to evaluate ESG funds. In his video, Mr. Gensler
asserts that the process for selecting an ESG fund should be as
straightforward as purchasing a carton of milk labelled fat-free and
suggests that he would cause the SEC to pursue new disclosure rules for
ESG-focused funds.

For its part, the private plaintiffs’ bar has initiated a number of actions
asserting greenwashing claims, although the focus of these claims to date
has not been ESG funds, but rather allegations that operating companies,
including corporations in the oil and gas, mining, and consumer goods
sectors, are making misleading claims about the climate-friendliness of
their operations or the products they manufacture. *See, e.g.,* *Jochims v.
Oatly Group AB*, 1:21-cv-06360 (S.D.N.Y. Oct. 26, 2021) (order granting
motion to dismiss claims that an oat milk company made materially false and
misleading statements about the company’s sustainability); *In re Vale S.A.
Sec. Litig.*, 2020 WL 2610979, at *9 (E.D.N.Y. May 20, 2020) (alleging
securities law claims that a mining accident demonstrated a Brazilian
mining company’s sustainability and safety claims were misleading); *Ramirez
v. Exxon Mobil Corp.*, 334 F. Supp. 3d 832 (N.D. Tex. 2018) (denying a
motion to dismiss claims that Exxon made material misstatements about proxy
costs for carbon).

What do these trends mean for litigation exposure faced by ESG funds and
their advisers and boards? Specifically, can we anticipate that private
plaintiffs’ lawyers and securities regulators will fix their sights on ESG
funds, embracing the greenwashing criticism by public commentators as a
basis for launching a wave of securities fraud litigation and enforcement
actions? Not necessarily. For a number of reasons, assertions that
climate-focused ESG funds are “not as green as they should be” may prove
challenging for the plaintiffs’ bar in establishing valid securities law
claims in the fund context. ESG fund disclosures differ in fundamental ways
from the ESG disclosures of typical operating companies. In light of these
differences, as well as established securities law principles governing
fund litigation, the types of theories recently asserted against operating
companies will not be readily transportable to the ESG fund setting, as
discussed below.
How ESG Fund Disclosures are Different

Under current SEC rules, the prescribed ESG-related disclosures of
operating companies are fairly narrow in scope. For investors, the
principal ESG-related disclosure focus area is climate risk, although there
also are disclosure requirements and/or guidance specific to conflict
minerals, resource extraction, mine safety, board diversity, human capital,
pay ratio and cybersecurity. Today, environmental disclosures largely are
pursuant to the SEC’s general principles-based disclosure framework and
grounded in materiality. As the SEC explained
<https://www.sec.gov/corpfin/sample-letter-climate-change-disclosures> in
its 2010 Interpretive Guidance on Disclosures Related to Climate Change
<https://www.sec.gov/rules/interp/2010/33-9106.pdf>, these disclosure
obligations under the 1933 and 1934 Acts primarily relate to the potential
impact *on the company* of climate change and regulatory developments to
address climate change. In the last several months, the SEC has sought to
encourage enhanced climate-risk disclosure
<https://www.ropesgray.com/en/newsroom/alerts/2021/October/SEC-Publishes-Sample-Comment-Letter-Highlighting-Climate-Change-Disclosures-SEC-Filings>
consistent
with the current disclosure framework by publishing a sample comment letter
on this topic and commenting on climate-related disclosures in selected
public filings. Required climate-risk disclosures are poised to increase,
with the SEC proposing new climate-related disclosure rules
<https://www.sec.gov/rules/proposed/2022/33-11042.pdf> on March 21, 2022, which
will require increased reporting on companies’ greenhouse gas emissions,
climate risks, the impact of those risks on financials, and management of
and strategies to mitigate those risks
<https://www.sec.gov/news/press-release/2022-46>.

A large number of public companies also make substantial voluntary
sustainability and corporate social responsibility disclosures—these go
well beyond those required by SEC rules—on their websites and/or in
stand-alone “corporate social responsibility” (CSR) or “corporate
sustainability” reports. These disclosures increasingly include both
historical quantitative metrics and forward-looking targets and are aligned
with third party frameworks. Many companies also voluntarily submit
environmental and other information to third party rankers and raters.

In the operating company context, allegations of greenwashing are most
likely to assert that the company has over-stated the climate-friendliness
or other positive impact of its operations, products, or initiatives—such
as the carbon footprint of its products or the impact of projects it would
finance with a “green bond.” From a securities liability exposure
perspective, with the increase in quantitative ESG disclosures, these types
of representations will increasingly be susceptible to measurement and
verification, and could have a readily-provable impact on the company’s
share price if shown to be over-stated.

By contrast, ESG funds, like all registered investment companies, are
subject to a different set of prescribed disclosure requirements than
operating companies under the Investment Company Act of 1940 and other
securities laws. For example, the new proposed SEC rules will apply to
public operating companies but not registered funds, although the SEC may
propose additional rules targeting registered funds in the future.
Registered ESG funds include open-end mutual funds, exchange traded funds
(ETFs), and a relatively small number of closed-end funds. As of 2020, the
ICI identified <https://www.ici.org/system/files/2021-05/2021_factbook.pdf> 592
ESG-focused mutual funds and ETFs with assets of $465 billion. In 2021
alone, 38 funds with sustainability mandates were launched in the U.S., 29
of which were equity funds and 25 were ETFs.

In their required public disclosures, registered ESG funds describe their
investment *objective* (typically a combination of financial return
objectives and incorporation of stated ESG principles in security
selection), the investment *approach* fund managers will take in seeking to
achieve those objectives (*i.e.*, the process they will follow in building
a portfolio of securities that will provide investment returns and further
the fund’s stated ESG principles), and the risks that may affect their
ability to meet these combined objectives. Significantly, as required by
law, registered funds also regularly disclose their full portfolio
holdings. Open-end mutual funds must disclose their portfolio holdings at
the end of each fiscal quarter, while ETFs are required to disclose their
portfolio holdings each day. 17 C.F.R. § 270.30b1-5 (requiring registered
management investment companies to file each quarter form N-Q, which
discloses the fund’s portfolio holdings); 17 C.F.R. § 270.6c-11(c)(1)
(describing ETF portfolio holdings disclosure requirements). The types of
representations that have been the focus of greenwashing litigation against
operating companies are not the types of statements that funds historically
have had a basis or reason to make.

For example, unlike an operating company that might tout the environmental
sustainability of its business model and disclose greenhouse gas emissions
reduction targets and a net zero commitment, a climate-focused fund is more
likely to explain how its investment process weights the relative carbon
impact—as well as the relative financial performance—of the companies it
considers for the portfolio. In describing its investment process, a fund
will often disclose the industry classifications and research services its
adviser utilizes in making ESG-focused investing determinations, or,
alternatively, the metrics and criteria the adviser has developed in-house.
>From a securities liability perspective, it would be challenging for a
shareholder-plaintiff to plausibly allege—at least based on typical fund
litigation evidence like portfolio holdings or performance results—material
misrepresentations in such process descriptions.

Moreover, ESG funds vary significantly from one another in the approach
they take to incorporate ESG principles into their investment process. As
part of an ongoing industry-wide effort in the U.S. to standardize
terminology for registered funds, industry groups have proposed some basic
categories of investment approach. These efforts appear to be coalescing
around three categories described by the Investment Company Institute (ICI)
<https://www.ici.org/system/files/attachments/20_ppr_esg_integration.pdf> as
“ESG exclusionary,” “ESG inclusionary” and “Impact.” ESG *exclusionary* funds
exclude companies or sectors that fail to meet certain criteria or that do
not align with the fund’s objectives, such as categorical prohibitions on
industries like weapons manufacturing, gambling, alcohol or fossil fuels.
Conversely, ESG *inclusionary* funds actively pursue positive
sustainability-related outcomes and financial performance through a focused
investment thesis that tilts their portfolios according to the relevant ESG
factors—without necessarily excluding particular sectors. Funds pursuing
*impact* investing strategies seek to generate positive, measurable, and
reportable ESG impacts alongside a financial return, often including
through activism in the operating companies in which they invest; these
impact funds are defined by their measurement, management and reporting of
these impacts.

These categories closely track those published by the UK Investments
Association
<https://www.theia.org/sites/default/files/2019-11/20191118-iaresponsibleinvestmentframework.pdf>
 and the Institute of International Finance
<https://www.iif.com/Press/View/ID/3637/IIF-Proposes-Alignment-Around-Fewer-Simpler-Sustainable-Investment-Terms-to-Enhance-Transparency-and-Bolster-Confidence-in-the-Integrity-of-the-Market->;
in contrast, some industry participants have suggested further breakdown of
these categories with additional labels like “limiting ESG risk” and
“seeking ESG opportunity,”
<https://www.morningstar.com/articles/1058990/the-morningstar-sustainable-investing-framework.>
or
the inclusion of categories that identify funds that utilize “corporate
engagement & shareholder action,” “norms-based screening,” and
“sustainability themed/thematic investing.”
<http://www.gsi-alliance.org/wp-content/uploads/2021/08/GSIR-20201.pdf.> Thus,
even among ESG funds, there can be substantial variation in the *types* of
disclosures made, given the variation in funds’ approaches to incorporating
ESG principles in their investment processes and the funds’ ESG and
investment goals.

By way of example, an “ESG Exclusionary” sustainable equity fund might
explain that its investment process seeks to screen out of the portfolio
all oil and gas companies and other companies engaged heavily in fossil
fuel production or heavy use, such as utilities. An “ESG Inclusionary”
sustainable fund might explain the relative weighting given to oil and gas
companies in the portfolio based on their progress towards reducing their
net carbon impact (while not excluding them outright). An “Impact” fund
might explain its objective to invest primarily in companies whose products
will have a measurable positive impact on the environment (while not
necessarily excluding any types of companies). Similarly, an “ESG bond
fund” might take an Exclusionary approach, declining to invest in any bond
issued by oil, gas or utility companies, whereas a green bond fund with an
Inclusionary or Impact approach might consider a bond of a high-emitting
company if the project financed by the bond appeared likely to bring about
net reductions in emissions.
How Greenwashing Assertions About ESG Funds Can Miss the Point

Assertions of “greenwashing” by ESG funds need to account for what funds
are actually required to—and consistently do—disclose, and the variations
in how different funds pursue sustainability objectives alongside financial
returns. Recent published assertions of greenwashing attempt to apply
one-size-fits-all metrics to funds which fail to account for these
differing investment approaches. These assertions are often based on a
flawed premise: they grade how “green” a fund’s holdings are, as measured
by the grader’s selected yardstick, rather than assess whether the fund is
managed consistent with the manner described in its prospectus and other
disclosures—the appropriate metric under the securities laws.

Such studies ignore the fundamental fact that different sustainable-focused
funds have very different investment approaches to meet different investor
preferences, and attempting to rank these funds on a single-variable margin
of “greenness” is not only misleading to the investing public, it also has
no basis under the securities laws. A shareholder asserting a securities
law claim against a fund must plausibly allege that the fund’s disclosures
contained material misstatements or omissions that would mislead a
reasonable investor about the nature of the fund, its investment approach,
or the risks that the fund might not meet its objectives, in light of the
total mix of information available to the investor about the fund. In
assessing claims of misleading disclosures, courts will recognize that the
total mix of information available includes the description of the fund’s
specific approach to incorporating ESG factors (*e.g.*, exclusionary vs.
inclusionary) and the fund’s regular disclosure of the securities it holds.

One recent example is particularly instructive in demonstrating what can be
missed in attempting to compare ESG investment products that might have
varying and divergent investment approaches by design. A recent report
authored by University of California, San Diego business students and
sponsored by As You Sow (AYS)
<https://www.asyousow.org/reports/ucsd-identify-greenwashing-funds>, a
non-profit shareholder advocacy organization, sought to develop and apply a
simplified analysis for identifying alleged greenwashing by ESG investment
products. The report examined 94 mutual funds and ETFs with “ESG” in their
name. It sought to use natural language processing to analyze the use of
key words in certain sections of the funds’ prospectuses and then compared
how those words were used to the ESG grade that AYS assigned to each fund
for a number of ESG categories; AYS’s ESG ratings
<https://www.asyousow.org/invest-your-values> give funds a grade of A
through F in categories including Fossil Free Funds, Gender Equality Funds,
Weapon Free Funds, Tobacco Free Funds, and Prison Free Funds. The report
found that it could not differentiate between language used by “good” ESG
funds—ones that received all C or higher grades across all metrics relied
upon by AYS—and the language used by “bad” funds—ones that received at
least one D or F grade.

Significantly, however, AYS’s “good” and “bad” fund ratings in each
category are based on scorecards that look primarily to fund holdings in a
number of categories, regardless of whether the fund actually claims to
avoid holdings in those categories as part of its stated investment
approach. The Fossil Free Funds rating <https://fossilfreefunds.org/about>,
for example, is based on the aggregate percentage of the fund’s holdings in
companies identified by a handful of outside organizations as oil, gas and
coal producers, owners of carbon reserves, and large consumers of fossil
fuels (*e.g.*, utilities). The ratings do not otherwise examine the funds’
investment strategies, sustainability objectives, or approaches to
achieving those objectives.

At most, this grading system could assess the success of funds with an
exclusionary approach in screening out companies considered to be non-green
investments using a specified metric. However, it cannot accurately capture
the truthfulness of an inclusionary fund that seeks to supplement
traditional energy investments with alternative, renewable sources; nor
would it reflect the intentions of an impact investing fund that seeks to
leverage its ownership in a corporation to promote positive change from
within. Put simply, not every “green” fund must be fully divested of fossil
fuel-related stocks in order to comply with its stated and disclosed
investment objectives. And even within the realm of exclusionary funds,
such a reductionist ranking cannot properly consider the specific criteria
identified *by that fund* as necessitating exclusion. Instead, any analysis
of a fund’s ESG success must be based on the disclosures made to the public
regarding its own objectives and whether they have been met.

Notwithstanding the lack of basis in the securities law standards, claims
like AYS’s of widespread “greenwashing” in the fund industry could trigger
the plaintiffs’ bar to launch a wave of costly meritless litigation and
ultimately be counterproductive for the sustainable investment movement.

Tellingly, the report concluded that “the linguistic pattern of the
prospectus of the fund has a relatively low correlation with its ESG
rating”—in other words, the study’s AI-based language analysis of fund
disclosures was inconclusive. Nevertheless, media reporting on the study
<https://www.bloomberg.com/news/articles/2022-01-11/esg-study-shared-with-sec-reveals-fund-labels-are-often-useless>
described
it as finding that “60 of 94 ESG funds failed to adhere closely to the
principles of environmental, social and governance investing.”

This dissonance between the report’s clear statement of inconclusive
results and the media’s interpretation of the report highlight the dangers
of unsupported claims of greenwashing based on inconclusive or misdirected
analyses. The news media amplify the message that ESG funds are somehow
misleading investors, but fail to engage with the underlying claims—thus
ignoring one-dimensional grading systems and the less-than-rigorous
methodologies.

In a similar vein, SEC Chair Gary Gensler’s March 1, 2022 video
<https://www.twitter.com/GaryGensler/status/1498708322677149700>, published
on Twitter as part of his “Office Hours with Gary Gensler” series, lumps
ESG funds into a single category, treating them all as synonymous with
“green,” “sustainable,” or “carbon-neutral” funds. He suggests that
selecting an ESG fund should be more like selecting “fat-free” milk at a
grocery store, where the grams of fat, an objective measurement, can easily
be ascertained by looking at the nutrition facts on the carton. But
according to Chair Gensler, in the context of ESG investing, “there is
currently a wide range of what asset managers might mean by certain terms,
and what criteria they might use.” He therefore concludes: “It is easy to
tell if milk is fat-free, it might be time to make it easier to tell
whether a fund is really what they say they are.”

Chair Gensler’s simple analogy ignores the many different ways that ESG
funds can pursue their goals and the range of investor values these
products seek to represent. Unlike fat-free milk, for which the
truthfulness of that descriptor can be ascertained by looking at one line
on a nutrition label, ESG funds cannot be evaluated or compared based on a
single, objective metric. ESG investors are not “shopping” for a uniform
type of product that can be compared and thus “labeled” based on a single
component like grams of fat. Just as grocery customers select differing
baskets of goods based on their various tastes and dietary needs (not just
on fat content), so too ESG fund investors come to the market with widely
varying values and financial goals they wish to see represented in their
investment baskets. Allowing for a variety of different ESG products that
pursue ESG objectives in different ways provides investors with numerous
options to meet their distinct goals. This is no different from how the
fund sector has long offered funds with widely varying investment
objectives and strategies to meet the varying financial goals and risk
tolerances of the investing public.
Additional Challenges Facing Greenwashing Claims under the Securities Laws

Aside from broad assertions of widespread greenwashing across the ESG funds
sector in studies like AYS’s, the discussion above highlights the
challenges posed by asserting securities violations based on such
theories—even if focused on a single fund—when applying established
principles from fund-related securities law authority.

It would be difficult in most cases to plausibly allege a materially
misleading misstatement or omission in a fund disclosure on the theory that
a “green” fund is not “green enough.” Plaintiff-shareholders claiming to
have been misled are deemed to have read a fund’s full disclosures, and
must explain how they were misled about the fund or its risks in light of
the “total mix of information” available to them. *See, e.g.*, *Basic Inc.
v. Levinson*, 485 U.S. 224, 231–32 (1988) (“[T]o fulfill the materiality
requirement ‘there must be a substantial likelihood that the disclosure of
the omitted fact would have been viewed by the reasonable investor as
having significantly altered the ‘total mix’ of information made
available.’”). For example, a shareholder could not claim to have been
misled by the word “green” in a fund’s name to believe the fund would never
invest in oil or utility companies, if the fund’s prospectus explained how
its investment process would be applied to such companies (without
necessarily screening them out altogether) and the fund’s regular holdings
reports clearly disclosed holdings in these types of companies. Likewise,
an investor could not claim to have been misled by a “green bond” fund
holding securities of carbon-emitting companies, so long as the bonds’
issuers and projects aligned with the *stated* investment objectives and
process articulated in fund disclosures.

Further, like all funds, ESG funds include in their disclosures detailed
explanations of the risks that could prevent the fund from meeting its
objectives—both financial results and ESG-related goals. Just as a fund’s
financial results may be highly dependent on macroeconomic and
portfolio-specific risk factors (*e.g.*, inflation, interest rates, credit
risk), so too various risk factors can affect a fund’s ability to construct
a portfolio that meets its specified ESG objectives (*e.g.*, technological
advances, government policy on ESG disclosures, accuracy of company
disclosures). The law is well-established that securities liability does
not attach when a fund’s financial under-performance results from the
manifestation of a fully-disclosed risk. *See, e.g.*, *Olkey v. Hyperion
1999 Term Tr., Inc.*, 98 F.3d 2, 9 (2d Cir. 1996) (“This court has
consistently affirmed Rule 12(b)(6) dismissal of securities claims where
risks are disclosed in the prospectus”) (collecting cases). The same will
hold true for alleged failures to meet stated ESG objectives resulting from
risks that the funds fully disclosed.

Moreover, plaintiff-shareholders in securities litigation would be required
to allege and establish *causation*—that is, that a drop in the fund’s
share price was caused by the alleged misstatement or omission in the
fund’s disclosures. *See, e.g., Dura Pharm. v. Broudo*, 544 U.S. 336, 343
(2005) (noting that securities laws exist, “not to provide investors with
broad insurance against market losses, but to protect them against those
economic losses that misrepresentations actually cause”). Given that a
fund’s share price is determined by the value of the securities in the
portfolio, rather than by investor sentiment as with typical secondary
market trading in operating companies, it can be difficult to establish
such a causal link in any case between a fund’s disclosures and its share
price. Doing so would likely be even more difficult where the disclosures
in question relate to the incorporation of ESG considerations in the
investment process, rather than typical financial risks.
Conclusion

For the ESG investing movement to reach its full potential, there must be
room in this highly-regulated marketplace for an array of investment
options to meet the variety of ESG values and priorities held by investors.
Just as different types of fixed income funds exist to satisfy investors’
varying appetites for financial risk and return (*e.g.*, municipal, core,
high-yield), so too a flourishing ESG fund sector will have room for
various approaches to responsible investing to respond to investors’
varying value sets. Clear disclosure of each fund’s distinct investment
approach remains the key to aligning fund objectives with the full panoply
of investor values. Increasing industry use of standardized disclosures, as
the SEC appears poised to require, will help investors more readily
distinguish among types of ESG funds, and thus more effectively compare and
contrast among true peer groups. But the use of inconclusive studies and
litigation as tools to pressure fund managers to pursue particular favored
approaches to ESG investing—especially without due regard for funds’
disclosed objectives and approaches—will find little support in the
securities laws, and will ultimately serve to undermine the responsible
investing movement.

-- 
*Gunnar Larson - xNY.io <http://www.xNY.io> | Bank.org <http://Bank.org>*
MSc
<https://www.unic.ac.cy/blockchain/msc-digital-currency/?utm_source=Google&utm_medium=Search&utm_campaign=MSc-Digital-Currency-North-America&utm_term=blockchain%20unic&gclid=Cj0KCQiAyJOBBhDCARIsAJG2h5ctwwMz0MRbVSk-LaYD-GMU5UgDSw7ynxbGr_a7SkaFAZzJc1-pzxEaAi4NEALw_wcB>
- Digital Currency
MBA
<https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovation-mba-1-5-years-or-3-semesters/>
- Entrepreneurship and Innovation (ip)

G at xNY.io
+1-646-454-9107
New York, New York 10001
-------------- next part --------------
A non-text attachment was scrubbed...
Name: not available
Type: text/html
Size: 39115 bytes
Desc: not available
URL: <https://lists.cpunks.org/pipermail/cypherpunks/attachments/20220426/4c05a61e/attachment.txt>


More information about the cypherpunks mailing list