According to the Ecological Restoration Business Association (ERBA), “Mitigation Banks is a highly regulated company that has proven to provide the highest quality and the most reliable compensation for environmental impact… and private investment in “green infrastructure” to offset the effects of economic growth. After purchasing a polluting website that he wants to regenerate, the mitigation banker works with regulators such as the MBRT (Mitigation Banking Review Team) and the CBRT (Conservation Banking Review Team), which approve the bank`s plans for constitution, maintenance and supervision. It is easier for developers to purchase credits from a licensed bank than it is to obtain administrative approvals that might otherwise take months to obtain. Given that climate change banks have already restored units in the area concerned in the borrowing process, there is little or no lag between the environmental impact of a watershed and its restoration on a bank site. This agreement is not the only one Donlin has entered into or will do to mitigate the effects of the mine. Donlin also signed an agreement with the Tyonek Native Corporation to facilitate conservation on 4,000 hectares of land. Donlin plans to sign another agreement with the Great Land Trust to acquire nine credits, the equivalent of nine hectares, to protect 4.5 hectares of wetlands in the Mat-Su Borough. There are currently a number of licensed mitigation banks in the United States.

According to the Regulatory Authority Information Tracking System (RIBITS) developed by the U.S. Army Corps of Engineers (USACE), there were more than 1,900 licensed banks as of May 2020. Mitigation Banking is a system by which liability for environmental damage is transferred from the authorization to the mitigation banker through a system of credit and charges in accordance with regulatory guidelines. A mitigation banker designs, restores, conserves and manages the area on a banking site and earns mitigation credits, which are then sold to a licensee or developer for a fee. Wyn Menefee is director of the Alaska Mental Heath Trust Land Office, and he says the agreement Donlin just signed with the Trust is complicated. It is also assumed that mitigation banks, contrary to some mitigations, when developers create their own mitigation sites near destroyed areas, tend to be far from impact sites and therefore cannot fully replicate the site concerned. Donlin Gold has just completed a long and costly environmental assessment led by the Army Corps of Engineers. As part of this audit, Donlin Gold was required to outline his plans to restore or mitigate wetlands that would disturb him.

To meet the mitigation requirements of the Army Corps and the State, the company proposed to protect wetlands elsewhere in Alaska, such as this agreement with the Alaska Mental Health Trust Authority. It is also questionable whether natural habitats and wetlands, which have been developed for centuries, can be artificially developed in just a few years. In some cases, the quality of these artificially developed wetlands has been found to be below average in terms of flower and wildlife diversity compared to their natural counterparts.