COP31 and the $4 trillion question: How to finance sustainable development
from All Things Sustainable
29m 55s
COP31, hosted in Turkey, marks a pivotal moment in global climate and sustainable development efforts, focusing on implementation of national climate commitments, climate finance, and adaptation resilience. The conference builds on the 2030 Agenda for Sustainable Development, where a $4 trillion annual funding gap—largely in infrastructure—remains unmet. Despite ambitious goals, private sector investment in developing economies, especially in Africa, remains critically low, with only 11% of infrastructure finance sourced from private capital. Dr. Mahmoud Mohadin, UN Special Envoy on Financing Sustainable Development, identifies key barriers: complex regulatory environments, inconsistent policy predictability, and a misalignment between perceived and actual financial risk. He emphasizes reforms such as simplified entry/exit rules, stronger property rights, transparent tax systems, and a robust pipeline of investable projects. The G-Fans Africa initiative supports this by promoting project development, capacity building, and carbon market growth. Climate action is framed through three pillars: mitigation (clean energy), adaptation (resilience in agriculture, water, and coastal systems), and loss and damage (post-disaster compensation for vulnerable nations). Though funding is available, it is often delayed, concentrated in advanced economies, and reliant on debt rather than equity-based private investment. The success of COP31 will not be judged by pledges alone but by measurable, tangible outcomes in financial flows and policy action, particularly post-conference. The event underscores the urgent need for global coordination, private sector engagement, and realistic, implementation-focused strategies to meet the 2030 SDG targets.
I'm Lindsay Hall and I'm Esther Wielden.
Welcome to All Things Sustainable, a podcast from S&P Global.
As your hosts, we'll dive into all the sustainability topics that are reshaping the business world.
Join us every Friday for in-depth analysis and interviews with leaders from around the globe.
Together, we'll break down big sustainability headlines and cut through the jargon.
COP31 cakes off in Untalia, Turkey this Monday, November 9th and runs through November 20th.
As a quick aside, the Republic of Turkey officially started encouraging use of the name "Turkia"
in international context in 2021 to better represent the country's culture and identity,
and the United Nations recognized the "Turkia" name in 2022.
As many of our listeners will know, the UN has three sister conventions, each designed to
address a separate but intertwined challenge, desertification, biodiversity loss, and climate
change.
What the UN describes as existential challenges to humanity.
COP31 is the UN's annual climate-focused conference of the parties to the United Nations
Framework Convention on Climate Change, also known as the UNF-Triple C.
What's on Zekit COP this year?
Well, a lot, in fact.
At a high level, COP31 will follow three main tracks.
COP31 focuses on a mission targets in implementation, and we'll hear how countries are delivering
on their nationally determined contributions or NDCs.
Those are countries planned to reduce national emissions and adapt to the impacts of climate
change under the Paris Agreement.
A second track will focus on climate finance, and specifically, delivering the new collective
quantified finance goal that was set at COP29 and 2024.
This goal, and the acronym here, is NCQG, calls for directing at least $1.3 trillion of
climate finance annually to developing countries from all public and private sources by 2035.
A third track at COP31 is all about adaptation and resilience.
Parties will focus on strengthening the resilience of vulnerable countries and communities against
climate risks.
Now, the headline priority for the COP31 presidency is driving implementation through cooperation
and collective action.
And Torquia has identified several priority areas.
These include electrification with a goal to increase the global electrification rate
to 35% by 2035.
They include zero waste and methane reduction with a goal to reduce the increase in waste
generation by 50% by 2035.
They also include resilient cities and buildings target, with a goal to reduce energy intensity
in the building sector by at least a quarter by 2035.
There's also green industrialization.
There, the goal is to increase the use of circular materials in the manufacturing and production
sectors to at least 15% by 2035.
Now an estimated 100,000 people will participate in COP31.
The event will convene heads of states, scientists, civil society, youth and business leaders from
around the world.
And in the last few years, we've seen a robust private sector presence at these gatherings.
Many companies including S&P Global participate in COP's.
And this speaks to a central question I hear.
What is the role of the private sector and what role does the public sector play in addressing
big societal challenges?
This is a topic we're going to explore with today's guest, Dr. Mahmoud Mohadin.
Mahmoud is UN's special envoy on financing sustainable development.
His career as an economist and finance leader includes time as executive director at the International
Monetary Fund or IMF.
He was Senior Vice President at the World Bank Group and he was Egypt's first Minister of
Investment.
He also served as the UN Climate Change High Level Champion for COP27, the Climate Change
Conference in his home country of Egypt that took place in 2022.
We'll hear today about what to expect from the upcoming COP31.
Mahmoud tells me what needs to change to get more private sector capital flowing to developing
markets.
He mentions the term OECD and that's the organization for economic cooperation and development.
First up though, we'll hear how the world is progressing toward the sustainable development
goals or SDGs to throw one more acronym at you.
World leaders convened in 2015 to adopt the UN's 2030 Agenda for Sustainable Development
and its 17 related sustainable development goals.
These SDGs act as a roadmap for achieving a better, more sustainable future for everyone
and they cover global challenges related to poverty, inequality, climate change, environmental
degradation, peace and justice all by 2030.
As we head into 2027, that 2030 deadline is just a few years away and I asked Mahmoud
in his capacity as UN Special Envoy on Financing Sustainable Development, what's your outlook
for delivering on this agenda, especially amid the geopolitical fragmentation and fiscal
constraints that have characterized 2026?
Here's what he had to say.
Well, as a person concerned with finance and implementation, I always use the evidence
and unfortunately, based on the numbers, we are only 36% on target to achieve the targets
of the SDGs and that means that we need to do a lot in terms of acceleration and acceleration
means finance, technology and incentives.
I see countries including big countries like China and India very much on target to achieve
some of the critical goals.
China can give hope to other countries of smaller population but it's all about acceleration
now.
I know that there are two teams working in the UN and beyond.
One is talking about acceleration, what can we do more on the finance, on investment,
on alignment of budgets, in dealing with issues related to debt which is taking through
the service, the chunk of the money and instead of putting it in human capital infrastructure
or putting it in debt service so there could be opportunities through debt swaps and others.
Many people are working now in the wonder that could really be obtained from investing
in technology and science to accelerate the implementation and others are working on
regulations.
Meanwhile, people with more practical and pragmatic minds, I hope that I'm one of them as
well, that would say, well, we'll do what we should be doing before 2030 but there is
life after 2030.
So post 2030 there is going to be some work in finishing the unfinished business and we
need to do more localization or regionalization for the second phase after 2030 and we need
to be more ambitious, not just in putting ambitious goals on targets but it's all about
means of implementation.
I hear a lot of numbers thrown around about the need for development finance.
Can you just put some numbers around it for our listeners?
Yeah, when we started the process back in 2015, the gap was around 2.5 trillion dollars
for developing economies and emerging markets to fulfill the goals and the targets.
This is 2.5 trillion per year and that needs to be mobilized from all sources including
official development assistance, private finance and the contributions from budgets.
The latest estimate of the gap is 4 trillion dollars and the majority of the gap is related
to the infrastructure sectors from energy to airports, airports, road networks, transport
systems, water and energy of course is part of the broader definition of infrastructure.
So this is the widening gap.
Some people would tell you that 4 trillion dollars to achieve all of these ambitious targets
to improve the quality of life and standards of living of the people around the world is
not really big if you're related to how much assets under management are available today.
The 4 trillion is just a tiny fraction of what is available of capital around the world.
What capital is not necessarily flowing to those areas of priorities?
Capital now, as you can see, is flowing to the AI ecosystem which is important but it's
not everything.
AI alone will not solve the needs for health services or education or dealing with job opportunities.
So what is being required is much more balanced approach in order to provide the necessary
funding for all of these necessary investments either in human capital or infrastructure or
investment resilience and the climate action.
And that's 4 trillion dollars now per year.
Yes.
For developing economies and emerging markets, assuming that the advanced economies will
take care of themselves.
Okay.
And let me ask, what is the expected breakdown of public versus private capital that would
ideally fulfill that need?
Let me give you an example from a recent report, especially, as I mentioned, the infrastructure
is responsible for the majority of the funds required for the SDGs because education would
require infrastructure and education facilities, schools, universities and they require energy
and they require roads as well to lead to this school, the same for hospitals.
The OECD and the African Union, in the case of the African continent, give us a very interesting
update that we require something like one hundred dollars.
and $70 billion of investments per year
in the African continent alone.
Currently, we have roughly 65 to 70 billion.
So this is basically half of what is being required.
And currently, of the figure they share with us,
48% of infrastructure finance is coming
from external sources.
41% is coming from the budgets of the state.
And 11% from the private sector, only 11%.
In an ideal world, if we have good public private partnerships
in place in terms of framework and ecosystem,
the private sector would should really
be doing the right thing by giving its contributors
a decent yield for whatever they are investing.
They should really be much more than 11%.
So we would really require lots of reforms for countries,
for the private sector, to have a better share.
Some people put a Ruru thumb to be arranging between 40%
to 70% of private sector finance for infrastructure.
What kind of reforms would help drive towards that higher
percentage?
Well, just yesterday I wrote an article
about investing in Africa with a focus on infrastructure.
First is entry rules and exit rules.
You wouldn't really go into a country that
has complications when it comes to registering your enterprise.
If it has complications in the exit rules as well,
if you are already done what you will need to be doing,
and you need to exit either to repatriate the profits
or to end the business to go somewhere else.
So the entry and exit rules need really
to be more simplified.
There are some countries that have been doing fantastic job
in this front in Asia.
Countries like Vietnam or Singapore or Thailand.
And some African countries, I would say,
countries like South Africa, or recently
could devour, be name, Morocco, and to have a rate extent
Egypt as well in these rules.
But it's not just about that.
Rule of law, protection of property rights.
You need to have a pipeline of bankable or rather
investable projects, because top private equity firms
will not just go and mobilize the resources
and their experts from one transaction.
Unless it's a very big transaction,
but a pipeline of investable projects
would be much more appreciated than just one small or big
transaction.
Markmoot said trust, certainty, and predictability
are also key to driving private sector investment.
So as much as the authorities, governments,
and regulatory agencies, can really make matters easier
to make sure that their standards of operations
are the kinds of standards that you are familiar with
when it comes to investments around the world.
Predictability of the tax systems and the tax policies,
predictability of the regulators like central banks,
or the financial regulatory authorities.
This would be very much appreciated.
In addition to that, the depth of the market,
not just the financial markets, but the markets at large.
And that's why it has been very much the case
that I'm working more now in Africa and the Middle East
that have been very much encouraging countries
for regional or sub-regional kind of collaboration.
Because some countries can offer opportunities
with decent size for capital to be injected.
Some smaller countries, if you are after a big energy
project or a big infrastructure project,
some sorts of aggregation will be appreciated.
Size matter in infrastructure.
- Okay.
You're reminding me of something I heard a lot
at Climate Week in New York just a few weeks ago,
which is a lot of people were talking about the need
for policy durability was the term.
- Yes, exactly.
You don't need the on and off or the surprises.
I wasn't the climate week and I listened to someone saying,
"Well, we don't need any surprises.
Even happy surprises, we don't need them.
Just make matters predictable for us
to do the proper risk management."
- And you mentioned that you're focusing
on Africa and the Middle East.
In your work as UN Special Envoy on Financing the 2030 Agenda,
talk to me about what is your geographic focus?
- Yeah, well, in my work, my function is global,
but of course, given that we cater more
for the developing economies and emerging markets
that gets me more into Africa, into Asia,
and the Latin American countries.
Now I see more and more tendencies for regionalization,
given the tension that we see around the world
in all of these kind of global tensions
between the incumbent powers and the emerging powers.
So many countries in the global south
are seeing opportunities through regional collaboration.
- Okay, your role includes sharing the G-Fans,
the Global Financial Alliance for Net Zero,
Africa Advisory Board.
- This is the Glasgow Finance Alliance for Net Zero
that was launched in the UK in COP26,
and it was led then by Mark Carney and the Marishapiro
and Mike Bloomberg.
Of course, Mark Carney is now the prime minister
of his home country, Canada.
Marishapiro is doing the work at the global level
and there are groups in Latin America, Caribbean, Asia,
and Africa and I'm responsible for the G-Fans Africa
as chair of the Board of Advisors to the G-Fans.
- So what do you see in that role
as some of the barriers to mobilizing institutional capital
in African markets?
- Actually, we have three priorities
and the three priorities would answer your question
different ways, one is playing a catalytic role
towards building pipeline of bankable investable projects.
They capital it there, but what we need is basically
these kind of projects aggregated in a way
to attract the asset owners, asset managers
and investors to invest.
The second one that we're doing is the capacity building
at large, this for governments and the private sector
and the third that we are doing more now
in the carbon credit markets.
One of the things that we are doing
is basically about the cost of capital
and while countries, including the US, OECD countries,
still manage to get decent finance with adequate cost
because of perception issues
and matters related to old legacies.
Many countries in Africa and the developing economies
are being dealt with based on perception
and there is an important report
that is getting regular updates from the international
financial institutions, that's called the GEMS report.
This is the database for credit, default and recovery
either sovereigns or private sector
and it's telling us that the default cases
are much better than being perceived,
actually less than 4% and the recovery,
even the cases of default are close to 75%.
But when it comes to the terms and conditions
of lending to developing economies,
it's dominated primarily with the perception.
So I think here there is a role for us not just to read reports
and to celebrate that the reality
or the actual risk is much better than the perceived risk
but how to bridge the gap between the reality and the perception.
And here it needs investments in the capacities
of sovereigns, of ministries of finance,
of line ministries to demonstrate their cases better,
we require better communication as well with the rating agencies
and better communication with market participants.
- Many of these challenges we've been hearing about
will be on the agenda when COP kicks off next week.
I asked Maup Mood about his own experience
at climate COP gatherings,
including his role as UN Climate Change High-Level Champion
for COP27 in Charmel Shake Egypt a few years back.
Here's what he said.
- My engagement started when I was at the World Bank
because part of my work
was on the sustainability at large
and the supporting the teams responsible for the COP.
But I was much more involved since COP26
that took place in Glasgow and the UK.
And since then for the last five years
I've been attending all of these COP's
either on the preparatory work
or in the summits themselves,
but with a focus on finance investment and it.
- And during your COP27 leadership,
I understand that you advocated for viewing climate change
through an African lens, through an African perspective,
and putting adaptation resilience on equal footing
with mitigation.
- First of all, heading into 2027,
what trends are you seeing in adaptation
and then also mitigation?
- Yeah, I'm very proud of course you can discount that
with the national bias to my own home country Egypt
in Charmel Shake.
I think there are things that have been developed nicely
that I like to reflect on because
lots of the importance for the past
but of the relevance to the current COP
that is going to be hosted in Antalya in Turkey
and the next COP in Addis next year.
The first one that we manage, I think,
to do a better job in linking climate action
to development action.
And there was unnecessary kind of dichotomy,
a false dichotomy between what we do in climate
and what is impactful for the development agenda.
If we're serious about the work and climate
is basic about three things.
Mitigation.
which is basically about investment in energy renewables
and the decarbonization, which has a great deal of matters
to do with access to energy, which is SDG seven,
one of the sustainable development goals.
The second one, which had been outlined for the first time
with clarity in Sharma Sheikh in COP27,
is basically about spelling out what adaptation means.
Because the specialists didn't really do a good job
in explaining what they mean by that,
assuming that everybody know what they are talking about
when it comes to investment and adaptation are easily.
But when you explain it, that this is better job
in investment in water management, in agricultural system,
in food systems, in the protection of shores
and coastal areas, in dealing with deforestation,
in dealing with the protection of cities and townships
from the desertification.
So you start to get some more attention
to the matter rather than talking about the matter
in a very generic abstract way.
So I think the Sharma Sheikh adaptation agenda
has since then being a good platform
to bring finance from the government sector,
which had so far had the majority of finance
and the good interest by the private sector now
in resilience adaptation solutions.
And the third one, based on the Paris Agreement,
is dealing with the loss and damage,
which is the third front in our war against planet.
So the first front line is mitigation,
the second is adaptation and the third is the loss and damage.
- Okay, so what do we more about the loss and damage,
which audience understand
about how you're thinking about that?
- Yeah, so the assumption here, by science,
if we're doing a good job in the mitigation
to protect the environment and the global system
and to keep the temperature below 1.5 degrees,
you will be in need for less in the investment
in adaptation resilience.
But we know that we are failing in that function
of dealing with the warming
because the emissions are higher than the thresholds.
And we are in a world that is definitely heading
for more than 1.5 degrees.
This means that we need to invest more
in the adaptation and in resilience.
If we're not investing adequately in adaptation resilience,
you get losses and you get damages.
It's like what we saw recently in Pakistan
when almost 40% of the land of the country was covered by water,
with losses and damages to agriculture, food production,
homes and the habitat.
So this is basically what we mean about the loss and damage.
That needs compensation and support,
especially the low income and developing country
that cannot deal with these kind of big losses.
The fund had been established, it was established in Egypt,
in Shah Masha'i, it was operationalized in Dubai, in COP28.
But so far, despite the many pledges and the commitments,
we are not seeing the flows of funds
to the institution as being promised.
What we need is to have more work,
to convince countries to inject more funds,
and to do more with institution investors,
including insurance, to support this fund.
So the money would come from both voluntary commitments
from governments and also from the private sector.
Yes.
Thank you for clarifying.
I'd like to look ahead to COP31.
What key questions do you have heading into this event?
These cops are very much interesting in terms of the way
that they conduct the agenda for the meetings.
So each chair has the responsibility as a president for two years.
The first year normally is more important than the second,
but the overlap with the successes as chair.
What we see here is, basically, for each chair,
they would say that we are going to be continuing
on our agenda of whatever left from the previous agenda.
That the second thing that there will be some particular topics
that each chair or a president of COP
would introduce as areas of emphasis.
Of course, there is an element of continuity.
This is COP31.
This means that we are building on promises and implementation
or lack of implementation of the promises
for the previous 30 cops.
But this cop in particular people lead it differently,
but my very personal view, there are three areas here
that could make this cop different.
One, the emphasis on waste management and zero waste.
And admire really what the Turks in particular
have been doing in this area.
Because it's a very big industry
and it's impacting everybody from the farmers to the industrials
to those who are living in their homes,
suffering perhaps from lack of quality of waste collection.
And there are many aspects of the work here
in terms of the green economy, in terms
as well of the waste to energy opportunities.
So I'm very happy with this kind of emphasis on the work
and the kind of ecosystem that is being built
under the leadership of Turkey.
The second one is about electrification
and new sources for energy and the investments
in innovation, batteries, greening the grids.
The third, which happens as we speak,
is access to finance.
And this is the pre-cop that's taken place
in the Pacific Islands.
'Cause you can always have all of these ambitious goals
on targets, but again, without adequate finance
to get stuck.
- That pre-cop gathering that Mahmoud just mentioned
to place October 5th through 8th.
Fiji, Tuvalu, and Australia partnered
to deliver the official pre-cop ministerial meeting
and the leaders event, which conveyed global climate
decision-makers in a Pacific ahead of COP31.
Access to finance was on the agenda at this event.
Strengthening financial access and support
for developing countries will also be a focus
at COP31.
Here's what Mahmoud had to say.
- So there is a great deal of emphasis
on the commitments of the advanced economies
and what we are doing on that front.
But I would say here that climate,
as in development finance, suffer from three things.
Insufficiency, because of the widening gap.
Insufficiency, because it takes really long, long time
until you get the money to the projects
from the sources of finance.
And third is the cost and the unfairness of finance,
because we are still very much suffering
from the fact that funding is there,
but is very much concentrated in advanced economies
and China.
And we are still very much relying
on debt instruments rather than public-private partnerships
and equity finance.
- What is the solution to this sort of reliance
on debt that you're seeing?
- We need to do a better job in the pipeline
of investable rather than bankable projects.
I can see today that many countries in the global south
are much more attractive to private sector finance
than others.
What did they do?
Basically, they did a better job
in improving their business environment.
They did a better job in the pipeline of investable projects.
They did a better job in the capacity building.
They did a better job in having a toolkit
and primarily with the multilater development banks
in order to encourage the private sector
through the risking tools, taking care of the first loss,
providing some sort of insurance and guarantees.
- Okay, and did I hear you correctly,
did you say investable rather than bankable projects?
- Yeah, investable means that it's not just going to be,
that is going to be more on the attraction
of the foreign direct investment
rather than borrowing abroad.
- Got it.
Well, thank you for sharing your expertise with me
and our global podcast audience.
- No, thank you so much.
- Today we heard about progress toward the U.N.'s
2030 Agenda for Sustainable Development
and the 17 Sustainable Development Goals.
The latest estimate is that $4 trillion
needs to be mobilized annually
to address the sustainable development goals
in emerging markets and developing economies
with much of that gap related to infrastructure.
Mahmoud explained the barriers
to getting more private sector investment flowing
to address that gap.
And he told us how conversations are unfolding
about investment in climate mitigation, adaptation,
and loss of damage.
This will be on the agenda at COP31
and at next year's COP32 in Addis Ababa, Ethiopia.
At the end of our interview, I asked Mahmoud
what will make this COP31 gathering a success?
And he said, "I'm always interested
in what will happen the Monday after."
He said, "You have all these conferences,
declarations, promises.
But what are we actually going to see happening differently?"
Well, that's the topic we'll be watching closely
on this podcast to see how COP31 outcomes unfold.
You can also follow along by subscribing
to our free weekly newsletter,
the S&P Global Sustainability Weekly,
and we'll include a link to that in our show notes.
You can also find information about S&P Global's events
at COP31 in those show notes.
Thanks for tuning in to this episode
of All Things Sustainable.
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See you next time.
(upbeat music)
Podcast Summary
Key Points:
COP31, the UNFCCC’s annual climate conference in Turkey, focuses on implementing nationally determined contributions, climate finance, and adaptation resilience.
A key target is mobilizing $1.3 trillion in annual climate finance by 2035, with the gap in development funding now estimated at $4 trillion per year.
Private sector investment remains low—only 11% of infrastructure finance in Africa comes from private sources—despite the need for a much higher share of 40–70%.
Key reforms to boost private investment include simplified entry/exit rules, stronger property rights, predictable tax and regulatory systems, and a pipeline of bankable, investable projects.
The UN’s G-Fans Africa initiative emphasizes building project pipelines, strengthening government capacity, and advancing carbon markets to bridge the gap between perceived and actual risk.
Climate finance must address three pillars
The pre-COP meeting in the Pacific Islands highlighted access to finance as a critical issue, reinforcing COP31’s focus on financial inclusivity and implementation.
Success at COP31 will be measured not by declarations, but by tangible, measurable changes in funding flows and policy action post-conference.
Summary:
COP31, hosted in Turkey, marks a pivotal moment in global climate and sustainable development efforts, focusing on implementation of national climate commitments, climate finance, and adaptation resilience. The conference builds on the 2030 Agenda for Sustainable Development, where a $4 trillion annual funding gap—largely in infrastructure—remains unmet. Despite ambitious goals, private sector investment in developing economies, especially in Africa, remains critically low, with only 11% of infrastructure finance sourced from private capital.
Dr. Mahmoud Mohadin, UN Special Envoy on Financing Sustainable Development, identifies key barriers: complex regulatory environments, inconsistent policy predictability, and a misalignment between perceived and actual financial risk. He emphasizes reforms such as simplified entry/exit rules, stronger property rights, transparent tax systems, and a robust pipeline of investable projects.
The G-Fans Africa initiative supports this by promoting project development, capacity building, and carbon market growth. Climate action is framed through three pillars: mitigation (clean energy), adaptation (resilience in agriculture, water, and coastal systems), and loss and damage (post-disaster compensation for vulnerable nations). Though funding is available, it is often delayed, concentrated in advanced economies, and reliant on debt rather than equity-based private investment.
The success of COP31 will not be judged by pledges alone but by measurable, tangible outcomes in financial flows and policy action, particularly post-conference. The event underscores the urgent need for global coordination, private sector engagement, and realistic, implementation-focused strategies to meet the 2030 SDG targets.
FAQs
COP31 focuses on climate action, with key tracks on implementing nationally determined contributions (NDCs), climate finance, and adaptation and resilience for vulnerable countries.
The new collective quantified finance goal (NCQG) targets at least $1.3 trillion in annual climate finance from all public and private sources by 2035 for developing countries.
Key priorities include electrification (aiming for 35% global rate by 2035), zero waste (reducing waste generation by 50%), resilient cities and buildings (reducing energy intensity by at least 25%), and green industrialization (increasing circular materials use to 15%).
Private sector investment is essential to bridge the $4 trillion annual gap needed in infrastructure, health, education, and climate resilience, especially in developing economies where public funding is limited.
Currently, only about 11% of infrastructure finance in Africa comes from the private sector, despite a need for significantly higher private investment to meet SDG targets.
Barriers include complex entry and exit rules, weak rule of law, lack of predictable tax and regulatory policies, limited pipeline of bankable projects, and persistent perception-based risk assessments that overlook actual financial stability.
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