To: Board of Directors; Executive Management; Legal, Risk, ESG, and Underwriting Leadership of: SMBC, Barclays, Standard Chartered, Credit Agricole, BCPE / Natixis, DZ Bank, LBBW, Bank of America, BBVA, Deutsche Bank, Goldman Sachs, ING, Intesa Sanpaolo, J.P. Morgan, Mizuho, MUFG, NBC, RBC, Santander, Scotiabank, Truist, Wells Fargo, Regions, ICBC, NordLB, Caixabank, HSBC, Morgan Stanley, Citibank, Allianz, Chubb, Swiss Re, AXA, Sompo, Zurich, Liberty Mutual, AIG, SCOR, Munich Re, Tokio Marine, Lloyd’s of London (Syndicates: Beazley, Hiscox, and Probitas), Helvetia, Generali, Hannover Re, Axis Capital, HDI-Talanx, Aviva, Argo, Old Republic, The Hartford, MS&AD, QBE, Travelers, and WR Berkley.

From: A global network of directly impacted communities and aligned civil society organizations, see full list of signers below.

March 16, 2026

Dear Members of the Board and Executive Leadership,

We write on behalf of a network of organizations and impacted communities with expertise in climate science, energy systems, human rights, biodiversity protection, and financial risk. We call on your institution to align its financing, underwriting, reinsurance, investment, and advisory activities with the science-based objective of limiting global warming to 1.5°C.1

This alignment requires the immediate exclusion of new or expanded fossil fuel projects, including liquefied natural gas (LNG) import and export terminals and associated methane gas infrastructure. In particular, we call on your institution to end and/or rule out all support for the CP2, CP3, Plaquemines LNG expansion projects proposed by Venture Global, as well as LNG expansion more broadly.

The International Energy Agency (IEA) concludes in its 2025 World Energy Outlook that “many of the LNG projects currently under construction are no longer necessary” in a pathway that limits global heating to 1.5˚C.2 The Intergovernmental Panel on Climate Change (IPCC) warns that emissions from existing unabated fossil fuel infrastructure are enough to exceed the remaining global carbon budget, and that continued installation of unabated fossil fuel infrastructure will lock-in greenhouse gas emissions.3 LNG, which is essentially methane, has significant lifecycle emissions. LNG terminals and related infrastructure are long-lived assets that can lock in further emissions and increase transition risk, with potential regulatory and reputational implications.4 Continued financial or insurance support for LNG expansion therefore raises material concerns regarding climate alignment, risk management, and consistency with publicly stated climate commitments.

The CP2 LNG terminal under construction in Cameron Parish, Louisiana, illustrates the environmental, regulatory, and financial liability risks associated with large-scale liquefied natural gas expansion in the United States. Developed by Venture Global LNG, the project is designed to export approximately 28 million tonnes per annum of LNG, which would make it one of the larger LNG export facilities proposed in the U.S. Gulf Coast, with operations projected to begin later this decade.5 Construction and related marine channel dredging have already resulted in documented environmental and economic impacts to commercial fishermen, shrimpers, crabbers, and oyster harvesters operating in traditional fishing grounds near the Calcasieu Ship Channel.6 Local fishing communities reported extensive sediment and dredge spoil discharge shortly before the 2025 shrimping season, and a Louisiana Department of Energy and Natural Resources investigation estimated that approximately 9,000–18,000 cubic yards of dredged sediment overflowed into fishing waters and public wetlands,7  impacting roughly 260 acres of marsh habitat8 and disrupting regional oyster production.9 These recent and legacy human rights harms from dredging and operational failures10 have significantly eroded Venture Global’s social license to operate.11 These impacts compound prior operational compliance concerns at Venture Global’s adjacent Calcasieu Pass LNG facility, which self-reported more than 2,000 air permit exceedances during its first year of operations and was documented to have been out of compliance with air permit requirements during the majority of its initial operating period,12 286 of the first 343 days.13 In addition to localized ecological and economic impacts, federal lifecycle analyses indicate that LNG export infrastructure of comparable scale generates greenhouse gas emissions comparable to dozens of coal-fired power plants annually, increasing exposure to climate transition risks, regulatory enforcement, and litigation.14 The CP2 project is located near predominantly low-income and historically marginalized coastal communities, increasing the potential for environmental justice and civil rights complaints under federal regulatory frameworks.15 Although the U.S. Department of Energy granted final export authorization for CP2 in October 2025, the project remains subject to ongoing legal challenges, including litigation filed by the Southern Environmental Law Center challenging federal approvals, and continues to face community opposition and scrutiny from regulators, investors, and insurers evaluating long-term liability exposure associated with LNG infrastructure.16

We request your institutions to conduct enhanced due diligence for all phases of CP2, CP3, Plaquemines LNG expansion projects proposed by Venture Global, and end support for LNG expansion projects that are fueling the climate crisis in accordance with the recommendations outlined below.

Immediate Moratorium on Fossil Fuel Expansion

Immediately end all financing, underwriting, reinsurance, investment, and advisory services for new or expanded coal, oil, and gas projects, including:

    • LNG export and import terminals;
    • Methane gas pipelines and associated infrastructure;
    • Projects across the full value chain (upstream, midstream, and downstream).

In addition, fossil fuel clients should be required to publish time-bound, measurable transition plans aligned with a 1.5°C warming limit and the Paris Agreement.17 Where clients fail to demonstrate credible and verifiable progress towards alignment, financial and insurance services should be withdrawn.

No Corporate-Level Services to Fossil Fuel Expansion Companies

Cease providing corporate group-level financial, insurance, and advisory services to any company that:

    • Is engaged in fossil fuel expansion, including LNG infrastructure; or
    • Is otherwise misaligned with a credible 1.5°C pathway and the objectives of the Paris Agreement.

Exclusion and transition policies should apply consistently across all subsidiaries, geographies, financial instruments, and reinsurance lines, to prevent circumvention.

At a minimum, companies listed on the Global Oil and Gas Exit List (GOGEL) and the Global Coal Exit List (GCEL) should be excluded from financing and insurance coverage.18

Community Protection, Accountability, and Capital Allocation

Ensure policies and practices:

    • Support affordable and accessible insurance for communities facing increasing climate-related risks;
    • Hold major polluters accountable for environmental, climate, and human rights harms;
    • Establish measurable targets demonstrating a clear scaling down of fossil fuel exposure and a corresponding scaling up of clean energy support.

Capital and underwriting capacity should be directed toward community-led and sustainable solutions, including sustainable renewable energy: primarily solar, wind, and hydropower where environmentally appropriate; energy storage, transmission and distribution system modernization, coastal restoration, and just transition initiatives that protect workers, Indigenous rights, and local economies.

Banks and insurers should also support the development of stronger laws and regulations that provide clarity and certainty while centering human rights, biodiversity, and ecological limits across energy and mineral value chains and refrain from engaging in lobbying efforts individually or as part of interventions led by parent trade associations intended to undercut rules that would advance and strengthen climate, environmental and rights compliance obligations.

Consistent with IPCC findings, carbon offsets, geoengineering, and large-scale carbon capture and storage (CCUS) should not be relied upon as substitutes for near-term and absolute emissions reductions.19

Human Rights and Biodiversity Safeguards

Require all clients to:

    • Respect and obtain Free, Prior, and Informed Consent (FPIC) for Indigenous Peoples;
    • Obtain meaningful consent from affected local communities;
    • Implement human rights due diligence aligned with the UN Guiding Principles on Business and Human Rights and the Universal Declaration of Human Rights.20

Financial and insurance services should be excluded or withdrawn from projects and clients that adversely affect:

    • Key Biodiversity Areas (KBAs);
    • International Union for Conservation of Nature (IUCN) protected areas (Categories I–V);
    • World Heritage Sites;
    • Ramsar Sites;
    • Other Critical Habitats.21

Where clients fail to meet these requirements—particularly in cases of persistent or systemic non-compliance—support should be withdrawn at both the project level and the corporate level.

Conclusion and Requested Response

We respectfully request information on whether your institution intends to adopt or amend policies consistent with the recommendations outlined above, including the scope of application and anticipated timelines by April 30, 2026.

We strongly encourage your ESG teams to meet with Community Leaders directly impacted by LNG expansion activities referenced in this letter. Their experience is critical to understanding how growth in this industry is hurting local and regional communities and economies.

We remain available for constructive engagement and technical clarification.

Sincerely,

Fishermen Involved In Sustaining Our Heritage
For a Better Bayou
Vessel Project of Louisiana
Habitat Recovery Project
Micah Six Eight Mission
Mossville Environmental Action Now MEAN
Gulf South Fossil Finance Hub
Freeport Haven Project
Mothers Rise Up
South Texas Environmental Justice Network
Japan Center for a Sustainable Environment and Society (JACSES)
Andy Gheorghiu Consulting
ReCommon
Campax
BankTrack
Jubilee Australia Research Centre
FoE Japan
South Durban Community Environmental Alliance
Les Amis de la Terre France / Friends of the Earth France
350 Colorado
Earth Ethics, Inc.
Women’s Earth and Climate Action Network
GreenFaith
Climate Action California
350 Seattle
Better Brazoria: Clean Air and Water
Razom We Stand
Conexiones Climáticas
Youth Climate Finance Alliance
Rivers & Mountains GreenFaith
Hip Hop Caucus
Zero Hour
Oil Change International
Oil and Gas Action Network
Santa Cruz Climate Action Network
Mid-Ohio Valley Climate Action
Nature Talk Africa (NaTA)—Uganda
350 Yakima Climate Action
Deutsche Umwelthilfe
MARBE SA
Seeding Sovereignty
Houston Climate Justice Museum
Climate Defenders
350 Silicon Valley
Stand.earth
Rinascimento Green
Turtle Island Restoration Network
Texas Campaign for the Environment
San Antonio Bay Waterkeeper
Third Act SoCal
Divest Oregon: Reinvest in a Fossil Free Future
Post-Landfill Action Network
Earthworks
Port Arthur Community Action Network(PACAN)
Bürgerinitiative gegen CO2-Endlager e.V.
Fossielvrij
Elders Coalition for Climate Action
The Climate Reality Project – Chicago Metro Chapter
Urgewald
Methane Action
The Raices Collab Project
Reclaim Finance
Allen+
Climate First!, Inc.
Boycott Bloody Insurance
Green America
Rainforest Action Network

  1. Paris Agreement, Articles 2.1(a) and 4 (2015)
  2. International Energy Agency (IEA), World Energy Outlook 2025
  3. IPCC, Sixth Assessment Report (AR6), Working Group III (2022), sections on remaining carbon budgets and fossil fuel infrastructure lock-in
  4. NewClimate Institute. (2021). Paris Alignment of the Gas Sector: Lock-in and Transition Risk in LNG Infrastructure.
  5. Federal Energy Regulatory Commission, CP2 LNG and CP Express Pipeline Project, Docket No. CP22-21-000; Final Supplemental EIS, A.1 Project Purpose and Need
  6. A critical analysis of the direct effects of dredging on fish – Accessed October 2025. http://onlinelibrary.wiley.com/doi/10.1111/faf.12218/full
  7. Cruice, Devin. “La.. Wildlife and Fisheries Says Silt in Big Lake Is Affecting Oyster Population; Fishermen Say Venture Global Dredging Accident Is to Blame.” https://www.kplctv.com, September 4, 2025. https://www.kplctv.com/2025/09/04/la-wildlife-fisheries-says-silt-big-lake-is-affecting-oyster-population-fishermen-say-venture-global-dredging-accident-is-blame/
  8. “Coalition Files Opening Brief Challenging FERC’s CP2 LNG Export Facility Approval in Louisiana.” Sierra Club, October 15, 2025. https://www.sierraclub.org/press-releases/2025/10/coalition-files-opening-brief-challenging-ferc-s-cp2-lng-export-facility
  9. Mayeur, Misha. “Louisiana Oyster Season Facing Crisis: Fisherfamilies in Cameron, LA, Cite Major Die off from Dredging and Dumping from Shipping, Refinery and LNG Projects.” Habitat Recovery Project, November 3, 2025. https://habitatrecovery.org/press-releases/oyster-opener
  10. Gas export spotlight: – operational. Accessed October 2025. https://labucketbrigade.org/wp-content/uploads/2023/01/Gas_Export_Spotlight_CameronCalcasieuPass.pdf
  11. Superhydrophobic silicone/graphene oxide-silver-titania nanocomposites as eco-friendly and durable maritime antifouling coatings – sciencedirect. Accessed October 2025. https://www.sciencedirect.com/science/article/abs/pii/S0272884223031644
  12. Venture Global’s operational failures & the impacts on fishermen gas export. Accessed October 2025. https://labucketbrigade.org/wp-content/uploads/2023/12/LABB-Monitoring-Report-r7.pdf
  13. Analysis of Venture Global Semi Annual Monitoring Reports. Accessed October 2025. https://labucketbrigade.org/wp-content/uploads/2023/08/Analysis-of-VG-Semi-Annual-Semi-Annual-Monitoring-Reports-May-2023-1-compressed.pdf
  14. Howarth, Robert W. 2024. The Greenhouse Gas Footprint of Liquefied Natural Gas (LNG). Energy Science & Engineering. https://scijournals.onlinelibrary.wiley.com/doi/10.1002/ese3.1934
  15. Stand.earth. 2024. Citi: Funding Fossil-Fueled Environmental Racism in the Gulf South. https://stand.earth/wp-content/uploads/2024/09/Citi-Funding-Fossil-Fueled-Environmental-Racism-in-the-Gulf-South.pdf
  16. https://www.selc.org/wp-content/uploads/2025/09/2025.09.05-Petitioners-Motion-For-Stay-1.pdf
  17. Paris Agreement, Article 4; UNFCCC guidance on aligning financial flows with climate goals. https://unfccc.int/files/essential_background/convention/application/pdf/english_paris_agreement.pdf.
  18. Global Energy Monitor, Global Oil and Gas Exit List (GOGEL); Global Coal Exit List (GCEL)
  19. IPCC AR6, Summary for Policymakers, findings on limitations and risks of offsets, geoengineering, and large-scale carbon removal.
  20. United Nations, Guiding Principles on Business and Human Rights (2011); Universal Declaration of Human Rights (1948).
  21. World Database on Protected Areas (WDPA); International Union for the Conservation of Nature (IUCN)