I. INTRODUCTION
The development of environmental standards at financial institutions is arguably among the most important international environmental law developments in the past two decades, yet these standards bear little resemblance to traditional visions of international law and may not even rightly be labeled international law at all. The standards are neither treaties nor custom, although they may reflect emerging principles of international law.1 Moreover, their development and implementation owe less to nation-states, the traditional monopolizers of international lawmaking authority, than to the financial institutions and civil society networks formed to influence those …