verview The Clean Development Mechanism (CDM) of the Kyoto Protocol1 revolutionized the development of international law by building a role for private sector entities directly into the implementation of a multilateral environmental agreement. The Protocol sought to harness the entrepreneurial spirit of private investors, project sponsors and carbon brokers to scour the planet for the most cost effective opportunities for greenhouse gas (GHG) emissions reductions. Furthermore, international accounting firms and management consultants would