Liberia is currently developing a Carbon Development Policy that will allow the country to trade carbon credits on international carbon markets. In October 2025, Liberia’s President, Joseph Nyuma Boakai, issued an executive order to establish the Carbon Markets Authority. The executive order also established a National Carbon Registry to track the issuing of carbon credits.
On 1 May 2026 Kenza Bryan reported in the Financial Times that the African Development Bank was putting pressure on the government to pass the Carbon Development Policy:
Liberian government departments have been told that a portion of the country’s funding from the African Development Bank (AfDB) — which has previously provided budget support and loans to the country’s private banks — depends on its approving a carbon sales framework, according to two people familiar with the matter.
The AfDB told the Financial Times that was involved in discussions with the Liberian government about “potential areas of support, including strengthening fiscal stability, promoting key sectors and enhancing climate governance frameworks”.
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The Liberian government did not respond to the Financial Times’ requests for comment.
Made in the USA
1: The Coalition for Rainforest Nations
In September 2024, the government of Liberia signed a Letter of Engagement with the Coalition for Rainforest Nations. According to the Liberia Environmental Protection Agency’s website, the agreement, “signifies Liberia’s commitment to participating actively in the global carbon market”.
Under the agreement, which runs for two years, the Coalition for Rainforest Nations would provide “technical support to enhance its capacity for monitoring, reporting, and verifying (MRV) greenhouse gas (GHG) emissions, aligning with the Paris Agreement standards”.
The CfRN would also strengthen “Liberia’s institutional framework to prepare for results-based payments through platforms such as REDD+ and ITMOs”. ITMOs are internationally transferred mitigation outcomes traded bilaterally under Article 6.2 of the Paris Agreement.
In December 2022, a company called ITMO Ltd was incorporated in the UK. The company’s sole director was Kevin Conrad, the founder of the Coalition for Rainforest Nations. The company was dissolved via compulsory strike-off in August 2025.
In May 2023, a company called ITMO Ltd LLC was incorporated in the tax haven of Delaware. On its website, the company states that,
ITMO Limited is a private company registered in Abu Dhabi, UAE. ITMO Limited LLC is registered in the USA. ITMO LTD. is registered in the UK. ITMO Limited is an affiliate of THE COALITION FOR RAINFOREST NATIONS.
A search on OpenCorporates gives no information about a company called ITMO Limited registered in Abu Dhabi.
ITMO Ltd is building the new global trillion-dollar Compliance Carbon Market (CCM) under the UNFCCC Paris Agreement, and sources, structures, and sells globally Compliant Carbon Credits (ITMOs) under Article 6, which you can buy now!
The photograph on the left is Kevin Conrad and Emmanuel Urey Yarkpawolo, executive director of the Environmental Protection Agency, at the signing of the Letter of Engagement in September 2024. The photograph on the right is Federica Bietta and Conrad, the co-founders of CfRN, with Yarkpawolo and James Marape, Papua New Guinea’s prime minister, one year later at the UN General Assembly in New York.
2: Gordian Knot Strategies
In January 2026, Liberia hired a company called Gordian Knot Strategies, a company incorporated in Oregon in June 2018, to provide technical and financial guidance. Gordian Knot Strategies is a climate financial consulting firm — in other words, it’s a carbon trading company.
Gordian Knot Strategies’ CEO, Sean Penrith, is a true believer in carbon markets, capitalism, and neoliberalism:
At Gordian Knot Strategies, I help clients untangle the world of climate finance. For over two decades, I’ve worked at the intersection of carbon markets, impact investment, and strategy, designing solutions that move billions in capital toward climate action.
According to a company statement, Gordian Knot Strategies will work with Liberia’s Carbon Markets Authority to support “capital mobilisation and market readiness” and “the development and operationalisation of Liberia’s national carbon market framework”.
Gordian Knot Strategies will also support “the design of robust governance, market infrastructure, and operational systems”. This will include providing “technical advisory support to assist the CMA in developing governance frameworks, institutional arrangements, registry, and MRV [monitoring, reporting, and verification] systems, and other core elements required for market readiness and integrity”.
There are few mentions of fossil fuels on the company’s website. Gordian Knot Strategies recycles the myth that carbon markets can “facilitate the transition away from fossil fuels”.
The reality is that decades of carbon trading has not made the slightest impact on the extraction and burning of fossil fuels. And companies that buy carbon credits do not decarbonise faster than those that don’t.
NGO reaction to the draft policy
The Financial Times reports that, “Liberian NGOs responded with alarm to a draft framework last month.”
The draft framework is marked “final”. It claims to ensure a “fair and equitable” distribution of the benefits from carbon trading. However, the policy would give between 50 and 90% of the benefits to the government and project developers.
This is despite the fact that under the 2009 Community Rights Law and the 2018 Land Rights Act, 70% of Liberia’s forests are legally owned by communities. The draft Carbon Development Policy appears to be stealing communities’ rights to the carbon in their forests.
Members of the NGO Coalition of Liberia, a network of more than 25 civil society organisations working in the forest sector, told the Financial Times that they had not been properly consulted on the policy. They are also concerned that the policy could endanger the right of communities to say no to projects on their land.
The policy could undermine Liberia's Nationally Determined Contributions (NDC). To avoid double counting, forests used for carbon credits can't count toward Liberia's climate commitments. The policy doesn't address this.
Investment treaty risks are real. Countries like Singapore are revising bilateral investment treaties so that even an MoU around carbon (one a government later decides not to pursue) can trigger punitive financial consequences. Liberia could be locking itself into agreements it can't safely exit.
The policy misinterprets Liberia's Revenue Sharing Law, applying it to community and private lands where it was never meant to apply. On community land, government is only entitled to tax revenue, not concession-style benefit sharing.
Communities have not been consulted by the government. When civil society conducted its own consultations last August, the message was overwhelming: respect our land rights.
There is no credible FPIC process described. No grievance mechanism. No safeguards framework with teeth. History tells us what happens next, companies claim verbal consent, development begins, and communities are left with nothing.
On 30 April 2026, the NGO Coalition of Liberia wrote to President Boakai to “urgently appeal” that he “defer the endorsement and signing of Liberia’s Draft Carbon Market Policy until a genuine, inclusive, and credible national validation process has been conducted”.
His Excellency Joseph Nyuma Boakai, Sr. President of the Republic of Liberia Executive Mansion Capitol Hill, Monrovia
April 30, 2026
Your Excellency:
On behalf of the NGO Coalition of Liberia, a network of over 25 Civil Society Organizations (CSO) working in the Forest Sector, extend sincere compliments and appreciation for Your Excellency’s leadership and continued commitment to advancing Liberia’s sustainable development agenda, particularly in the areas of climate action and natural resource governance.
We write, with utmost respect, to urgently appeal that Your Excellency defer the endorsement and signing of Liberia’s Draft Carbon Market Policy until a genuine, inclusive, and credible national validation process has been conducted.
While recognizing the efforts made by the Environmental Protection Agency, the Carbon Market Authority, and the Forestry Development Authority in advancing this policy, we express growing concern that the process leading to its “final validation” has been significantly truncated especially with respect to the meaningful participation of key stakeholders. In particular, we note that the validation process at both the technical and national levels did not involve the full and meaningful participation of key stakeholders. Forest-dependent communities, civil society organizations, and other critical actors — whose engagement is essential to the legitimacy, implementation, and long-term success of this policy — have not been adequately consulted in a manner that meets the standards of inclusivity, transparency, and informed consent. But most importantly, there remain fundamental disagreements on a number of critical issues that require further discussion.
Your Excellency, Liberia’s carbon market policy is not a routine administrative instrument. It is a foundational framework that will determine how Liberia’s forests, lands, and carbon assets are governed, monetized, and potentially committed under long-term agreements. Importantly, this policy framework will also serve as the basis for developing future legislation on carbon marketing and a broader national climate law. As such, any gaps, weaknesses, or exclusions at this stage risk being carried forward and institutionalized within binding legal frameworks that will shape the sector for generations.
The implications for national sovereignty. community land rights. benefit-sharing, and intergenerational equity are therefore profound.
We respectfully note that endorsing such a policy without a robust national validation risks:
Undermining the legitimacy and public trust in national policy, as well as damaging the international reputation of Liberia, given that the policy potentially undermines Liberia’s ability to maintain its bilateral investment treaties and fulfil its Nationally Determined Contributions under the Paris Agreement;
Exposing communities to arrangements that they neither fully understand nor have consented to;
Creating conditions for inequitable or unfavourable carbon agreements that may be difficult to renegotiate;
Embedding structural gaps into future legislation on carbon markets and climate governance.
It is therefore both prudent and in the national interest to ensure that this policy is grounded in a process that reflects true national consensus - not one shaped by compressed timelines or external pressures.
In this regard, we respectfully urge that:
The endorsement and signing of the Draft Carbon Market Policy be deferred;
A comprehensive national validation process be convened, ensuring the full and effective participation of’communities, civil society. and other stakeholders across affected regions;
Adequate time and space be provided for technical review, public dialogue, and incorporation of stakeholder inputs before final approval.
We remain confident in Your Excellency’s commitment to protecting the interests of the Liberian people and ensuring that the country’s natural resources are governed in a manner that is just, transparent, and beneficial to all.
Please accept, Your Excellency, the assurances of our highest consideration.
A quick follow-up, Chris. Redd-Monitor itself cites the Oeko-Institut study, whose authors concede that 'it would be inherently challenging to develop a robust and representative study design that would be suitable to empirically test whether the use of carbon credits has a causal effect on internal emission reductions.' That's an admission of methodological limits, not a finding. It can't carry the weight of the claim being made.
Chris Lang’s piece repeats a familiar but incomplete critique of carbon markets. After having spent two decades in this space, I believe I have a perspective here. It is one thing to argue that carbon markets must be better governed; it is another to claim that decades of carbon trading have made no difference at all and that companies buying carbon credits do not decarbonize faster. That assertion does not reflect the evidence.
Trove Research, now part of MSCI, examined the emissions performance of more than 4,000 global companies and found that companies using material quantities of carbon credits were, on average, decarbonizing at twice the rate of companies that did not use them. MSCI’s later publication on the same topic found that carbon-credit users were more likely to disclose emissions, reduce Scope 1 and 2 emissions, reduce emissions intensity, set climate targets, and earn more revenue from low-carbon activities.
That matters because it directly contradicts the claim that carbon credits function as a “license to pollute.” The evidence cited by MSCI points in the opposite direction: voluntary carbon credit use has been associated with faster internal emissions reductions, not slower ones.
A more honest debate would acknowledge the real question: not whether carbon markets are perfect, but whether they can be structured with strong integrity, community rights, and transparent benefit-sharing so that they mobilize capital for climate action in the Global South. That is the case many of us are making. Indeed, that was the entire desire of us to help Liberia design a carbon market with first degree integrity.
Carbon markets are not a substitute for regulation, industrial decarbonization, or fossil-fuel phaseout. But dismissing them outright ignores the empirical evidence and overlooks their potential to channel finance from the Western world toward climate action and development in the Global South.
P.S. I am a Zimbabwean who studied in South Africa. My firm, Gordian Knot Strategies, is registered in Portland OR USA and works in South America, Asia, Africa, Europe, and the U.S.
A quick follow-up, Chris. Redd-Monitor itself cites the Oeko-Institut study, whose authors concede that 'it would be inherently challenging to develop a robust and representative study design that would be suitable to empirically test whether the use of carbon credits has a causal effect on internal emission reductions.' That's an admission of methodological limits, not a finding. It can't carry the weight of the claim being made.
Chris Lang’s piece repeats a familiar but incomplete critique of carbon markets. After having spent two decades in this space, I believe I have a perspective here. It is one thing to argue that carbon markets must be better governed; it is another to claim that decades of carbon trading have made no difference at all and that companies buying carbon credits do not decarbonize faster. That assertion does not reflect the evidence.
Trove Research, now part of MSCI, examined the emissions performance of more than 4,000 global companies and found that companies using material quantities of carbon credits were, on average, decarbonizing at twice the rate of companies that did not use them. MSCI’s later publication on the same topic found that carbon-credit users were more likely to disclose emissions, reduce Scope 1 and 2 emissions, reduce emissions intensity, set climate targets, and earn more revenue from low-carbon activities.
That matters because it directly contradicts the claim that carbon credits function as a “license to pollute.” The evidence cited by MSCI points in the opposite direction: voluntary carbon credit use has been associated with faster internal emissions reductions, not slower ones.
A more honest debate would acknowledge the real question: not whether carbon markets are perfect, but whether they can be structured with strong integrity, community rights, and transparent benefit-sharing so that they mobilize capital for climate action in the Global South. That is the case many of us are making. Indeed, that was the entire desire of us to help Liberia design a carbon market with first degree integrity.
Carbon markets are not a substitute for regulation, industrial decarbonization, or fossil-fuel phaseout. But dismissing them outright ignores the empirical evidence and overlooks their potential to channel finance from the Western world toward climate action and development in the Global South.
I would be more than happy to discuss directly with you if you want to discuss further. I am at spenrith@gordianknotstrategies.com
Thanks,
Sean
P.S. I am a Zimbabwean who studied in South Africa. My firm, Gordian Knot Strategies, is registered in Portland OR USA and works in South America, Asia, Africa, Europe, and the U.S.