Taking environmental, social and governance (ESG) factors into account during the investment process involves certain unique challenges, including inconsistent terminology, disparate methodologies and insufficient data. Nevertheless, a fundamental compliance rule continues to hold true for advisers that venture into ESG territory: “Say what you do, and do what you say.” Goldman Sachs Asset Management, L.P. (GSAM) recently ran afoul of that dictate on both counts. In a recently settled enforcement proceeding, the SEC claimed that GSAM failed to adopt appropriate policies and procedures for governing certain ESG products. Moreover, after it did adopt ESG policies and procedures, it failed to follow them. This article describes the alleged compliance shortcomings and the terms of the settlement. See “Typical Deficiencies Targeted in SEC Examinations of Advisers’ ESG‑Related Policies, Procedures and Disclosures” (Oct. 11, 2022); “Misleading ESG Claims Can Result in Significant SEC Penalties” (Aug. 16, 2022); and “Core Features of the SEC’s Proposed ESG Rules and the Ethos Driving Its Release” (Jul. 26, 2022).