Effective date: 18 July 2026. These are the current published terms for Carbon Trader® website and platform use.

Part 8 - AML/CFT and KYC Statement

1. Purpose

Carbon Trader applies AML/CFT, sanctions, fraud and customer due diligence controls to protect clients, counterparties, the platform and the financial system.

1A. Our AML/CFT programme

Carbon Trader maintains a written money-laundering and terrorism-financing risk assessment and AML/CFT programme under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009, formally adopted by director resolution on 18 July 2026, with a designated compliance officer responsible for its operation, annual internal review and periodic independent audit. Identity verification and screening are delivered through Sumsub, including government-ID document checks, biometric liveness, beneficial-owner identification for entities, and sanctions and PEP screening at onboarding and on an ongoing basis. The Department of Internal Affairs is the AML/CFT supervisor for businesses of this type.

2. Customer due diligence

Carbon Trader may collect and verify identity, address, company, NZBN, directors, beneficial owners, senior managers, authorised users, source of funds, source of wealth, source of credits, bank details, registry details and transaction purpose.

3. Enhanced due diligence

Enhanced checks may be required for higher-risk users, large transactions, unusual settlement patterns, complex ownership, offshore parties, sanctions exposure, PEP connections, high-risk jurisdictions, third-party funding, unclear credit origins, unusual forestry arrangements or other risk factors.

4. Ongoing monitoring

Carbon Trader may monitor transactions, activity, listings, wallet records, API usage, payments, registry transfers, logins and communications.

5. Refusal and delay

Carbon Trader may refuse onboarding, pause transactions, withhold settlement, suspend accounts or report activity where legally required or risk-based controls require it.

6. Suspicious activity

Carbon Trader may report suspicious activity to the relevant authority. Carbon Trader may be legally prohibited from telling users that a report has been made.

7. User obligations

Users must provide accurate information and promptly update changes. Users must not use Carbon Trader for money laundering, terrorism financing, sanctions evasion, fraud, tax evasion, market manipulation or illegal activity.