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Norway’s Global Pension Fund, a sovereign wealth fund worth over $300 billion, is the second largest in the world. Beginning in 2004 it adopted ethical guidelines intended to promote sustainable development and, in particular, to minimize the risk of complicity in serious human rights violations. The turn to ethical investment strategies to promote corporate social responsibility can be seen as an important supplement to emerging regulation of multinational corporations — or as an admission that regulation has failed. In the case of Norway, it has seen controversial decisions such as disinvestment from Wal-Mart and a decision not to disinvest from companies operating in Myanmar (Burma). This article discusses the creation and work of the Council on Ethics, focusing on the ambiguous legal and ethical meanings of “complicity” and the uncertain impact that disinvestment has on behavior. The turn to ethics offers an opportunity but also an opportunity cost: ethics can be a means of generating legal norms, through changing the reference points of the market and providing a language for the articulation of rights; yet they can also be a substitute for generating those norms, providing illusory rather than genuine accountability.