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Eligibility Criteria for Green Funding

Convention on the Conservation of Migratory Species EIA Considerations for Banks

The Convention on the Conservation of Migratory Species of Wild Animals (CMS), adopted in 1979, establishes critical protections for migratory wildlife and their habitats across international borders. For financial institutions, this treaty carries significant implications when financing projects that may intersect with migratory routes or critical habitats. The banking sector must incorporate CMS considerations into environmental due diligence processes, particularly for infrastructure, energy, and agricultural projects that could disrupt ecological corridors or seasonal movement patterns.

When conducting environmental impact assessments, banks should pay special attention to several key aspects. First, project evaluations must identify potential impacts on species listed under CMS Appendices I and II, ranging from marine mammals to migratory birds. Second, assessments should account for seasonal variations, as many species only occupy habitats temporarily during migration. Third, the transboundary nature of migratory species requires coordination with conservation authorities across multiple jurisdictions. Particular scrutiny should be given to linear infrastructure projects like roads, power lines, and wind farms that may create barriers to movement.

Non-compliance with CMS obligations presents multiple risks for financial institutions. Regulatory consequences may include violations of national laws implementing CMS protections, potentially resulting in project delays or cancellations. Reputational risks emerge when banks finance projects harming iconic migratory species, which often attract significant public attention. Financially, inadequate consideration of migratory species may lead to stranded assets or loan defaults when projects require costly retrofits to address ecological impacts. Conversely, banks that proactively address CMS requirements can position themselves as leaders in sustainable finance while mitigating these risks.

To effectively manage CMS-related exposures, financial institutions should enhance their due diligence frameworks in several ways. Spatial analysis tools can help identify critical habitats and movement corridors early in project screening. Financing criteria should include seasonal timing considerations to avoid critical migration periods. Collaboration with ecological experts can improve impact assessment quality, while engagement with range states ensures compliance across jurisdictions. As international biodiversity frameworks evolve, banks that systematically integrate CMS considerations will be better positioned to navigate emerging nature-related financial risks and disclosure requirements.

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