Effective date: 18 July 2026. Last revised: 28 October 2026. These are the current published terms for Carbon Trader® website and platform use.
Part 8 - Identity Verification and AML/CFT 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 is conducted in-house under the Identity Verification Code of Practice 2026: a customer's full name and date of birth are verified from a certified copy of an identity document (certified by a trusted referee such as a Justice of the Peace, lawyer or chartered accountant within the previous 12 months), or from original documents sighted in person, and reviewed by a designated person. From 9 October 2026 this verification takes place when a transaction first enters Carbon Trader-managed escrow (see section 1B) and not when an account is created; an account's email address is confirmed with a one-time code at registration. Every customer whose identity is verified is screened against the New Zealand Sanctions Register and the United Nations consolidated list, asked to declare politically exposed person status, and assigned a risk rating that determines whether enhanced due diligence applies. The Department of Internal Affairs is the AML/CFT supervisor.
1B. When identity is verified
An account is created with a name, an email address and a password, or by signing in with a Carbon Tracker® account. A person may browse the marketplace, create a listing, record bank and NZETR account details and post a buyer request without identity verification. In none of those cases does Carbon Trader hold funds or transfer value for that person.
Identity is verified once, when a transaction first enters Carbon Trader-managed escrow:
- for a buyer, before Carbon Trader issues the invoice for the purchase;
- for a seller, before Carbon Trader releases sale proceeds. A listing may be sold and the buyer's funds received into escrow first; the proceeds are held until the seller's identity is verified;
- for any user, before a withdrawal from a custody wallet is processed.
Carbon Trader does not issue an invoice to, release proceeds to, or process a custody withdrawal for, a person whose identity has not been verified. For an organisation, trust or estate the persons who own, control or have authority to bind it are verified. Source-of-funds and source-of-credit questions, enhanced due diligence and holds under sections 3 to 5 may apply to any transaction, and Carbon Trader may require verification earlier where it considers the risk warrants it.
From 28 October 2026 a seller may choose to sell a listing directly instead of through escrow, where the units are in the seller's own NZETR account. In a direct sale the buyer pays the seller and the seller transfers the units themselves; Carbon Trader introduces the parties but holds neither the money nor the units and is not a party to the sale, so it does not verify the identity of the buyer or the seller. Each party deals with the other at its own risk.
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, 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.