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REDD+ is already developing private sector engagements, making rights to sell and benefit from reduced emissions (carbon rights) a crucial issue. Our review of private sector REDD+ projects reveals tendencies for legal arrangements that reinterpret tenure law so as to bundle the new commodity of carbon regulation with existing rights to tangible resources. Provisions for benefit sharing, particularly those aimed at addressing the underlying causes of forest degradation, are often vague or missing. Given the size and duration of private REDD projects, this has far reaching and long term implications for communities and countries.