Legal and platform information

Client Money, Escrow and Custody Controls

Controls for client settlement accounts, Carbon Trader-managed escrow, digital wallet records and custody-related workflows.

Effective date: 30 May 2026. These are the current published terms for Carbon Trader® website and platform use.

Part 18 - Client Money, Escrow and Custody Controls

1. Purpose

This schedule explains the operational controls that apply to Carbon Trader-managed escrow, client settlement accounts, digital wallet records and custody-related workflows.

2. Client settlement account controls

Carbon Trader maintains a designated escrow / client settlement account for transaction funds. The account is used only for settlement purposes, fee deductions, refunds, reversals, agreed disbursements and related transaction payments.

3. Segregation

Carbon Trader records client settlement funds separately from ordinary operating funds in platform records. Where operational banking requires funds to be held with a bank, Carbon Trader maintains records showing the relevant transaction and beneficial party.

4. Reconciliation

Carbon Trader reconciles buyer funds, seller proceeds, Carbon Trader fees, pass-through costs, refund amounts and bank balances against transaction records.

5. Dual control

High-value releases, manual amendments, refund instructions, settlement account changes, bank account changes, NZETR custody actions and exceptional adjustments are subject to internal approval controls.

6. Settlement instructions

Settlement instructions identify:

  • buyer and seller;
  • quantity and unit type;
  • gross price;
  • fees and GST;
  • pass-through costs;
  • net seller proceeds;
  • buyer payment account;
  • seller payment account;
  • NZETR account names and numbers;
  • timing;
  • conditions;
  • what happens on buyer default or seller default.

7. Custody of NZUs

Where NZUs are transferred to Carbon Trader’s NZETR account for escrow, Carbon Trader records the beneficial transaction, seller, buyer, quantity, date received, date transferred onward, evidence references and any discrepancies.

8. No general deposit-taking

Carbon Trader-managed escrow is for transaction settlement. It is not a deposit product, savings product, bank account, investment scheme or promise of return.

9. Holds and freezes

Carbon Trader may hold funds or NZUs if required for AML/CFT, sanctions, fraud, court order, regulator request, banking recall, registry issue, dispute or operational risk. Carbon Trader will release or return funds and credits only when legally and operationally appropriate.

10. Interest and bank charges

Unless transaction terms state otherwise, no interest is payable to users on funds held for settlement. Bank fees, transfer fees, foreign exchange costs and external costs may be deducted or passed through where applicable.

Contact

For questions about this policy, contact Carbon Trader at info@carbontrader.nz.