ESG strategies are increasingly popular with investors and hedge fund managers. Thus, in 2020, the SEC’s Division of Examinations (Examinations) stated that it planned to review ESG investing with “particular interest” as part of its annual Examination Priorities. In fact, Examinations’ scrutiny of ESG investing may have already begun. A number of fund managers reported receiving extensive document requests from Examinations – such as the sample version contained in this article – about their ESG investing practices, including their disclosures, marketing, use of metrics, internal controls and other policies. In light of that scrutiny, fund managers must ensure that they know the risks associated with ESG investing and take steps to mitigate them. To understand the scope of the SEC’s efforts in this area to date and going forward, the Hedge Fund Law Report interviewed hedge fund practitioners advising managers with respect to SEC exams that have covered ESG investing. This article analyzes the SEC’s recent approach to ESG oversight, potential ESG‑related risks for managers facing SEC scrutiny and steps managers can take to mitigate those risks in advance. See “Division of Examination’s 2021 Exam Priorities: New and Emerging Focus Areas (Part One of Two)” (Apr. 15, 2021); and “Focus Areas for Private Fund Managers From OCIE’s 2020 Exam Priorities” (Feb. 27, 2020).