The SEC charged Invesco Advisers, Inc. with violations of the Advertising Rule and Compliance Rule under the Investment Advisers Act for making misleading statements about the percentage of company-wide assets under management (AUM) that integrated environmental, social, and governance (ESG) factors in investment decisions. The firm agreed to pay a $17.5 million civil penalty. The case highlights the importance of ensuring that ESG-related claims operate in parallel with internal written policies and procedures that include defined terms to be used in evaluating and supporting such claims made to existing and prospective investors.