# Know-Your-Business (KYB), Anti-Money Laundering (AML), Anti-Bribery and Corruption (ABC) To safeguard against money laundering, we have implemented rigorous review procedures to assess risks. This includes an understanding of risks, comprehensive customer due diligence, and Know-Your-Business checks to vet users on our platform. All reports of potential bribery or suspicious activity must be directed to . Responsibility for tracking, monitoring, and enforcing the KYB, AML and ABC policies for OCP users (Project Developers, Expert Panels, VVBs, dMRV providers) and OCP employees sits with Rio Richardson, Chief Product Officer, who is responsible for escalating to the OCP Advisory Board where required. Responsibility for tracking, monitoring and enforcing the KYB, AML and ABC policies for beneficial owners, significant investors and OCP Advisory Board members sits with Chris Fort, Chief Operating Officer and the oneshot.earth legal counsel. ## Know-Your-Business (KYB) KYB checks are conducted and approved for anyone who wishes to (a) propose a new project, (b) provide data for a project (including on verification), and (c) hold, transfer, and retire credits. * For KYB vetting, general information is collected and passed through for verification. The general information includes the business name (as registered with the IRS), Address (HQ if it is a larger company), taxpayer identification number associated with the business, and a list of people related to the business (the main personnel interacting with the OCP). * This data is cross-referenced with Secretary of State filings to verify state registrations and the business's operational footprint. The business address, web presence, and government watchlists get scanned, and any potential risks are flagged and compiled into a comprehensive report, determining whether the account is approved or rejected. * Email addresses are screened and verified before allowing access for users that do not fit into the above categories (i.e., experts overseeing methodology creation and not involved in issuing credits). * Additional diligence checks, such as vetting company funding sources and leadership, will be conducted when necessary. #### Continuous Monitoring * We maintain detailed data of all OCP carbon credit transactions, and any suspicious activities will be immediately flagged. If a flag comes in during the initial KYB screening, the account will not be permitted. If there's a flag raised during a transaction on the OCP, the account will be frozen until further investigation occurs. * All data on KYB checks will be stored for record-keeping for at least 5 years. ## Anti-Money Laundering (AML) Policy Money laundering defined is the process of concealing the origins of money obtained through illegal activities and making it appear as if it came from legitimate sources. As they pertain to carbon markets, this might look like: * Shell companies purchasing credits with illicit funds * Multiple rapid trades between related entities to obscure sources of funds * Purchase of credits at inflated prices to justify large transfers * Mixing legitimate and fraudulent credits to obscure origins High Risk Indicators: * Unusual trading patterns or volumes * Complex ownership structures * Transactions with high-risk jurisdictions * Inconsistent business profiles * Reluctance to provide verification documents #### **Mitigation and Training** * All employees must review anti-money laundering policies and risks as outlined here. * We will adhere to international and relevant national AML regulations where trading occurs. * Our team of software engineers is trained in flagging accounts and transactions that seem out of the ordinary in order to be able to report suspicious activities. This consists of detecting patterns in transaction data, account activities, and user behaviors specific to carbon credit trading. * They will also maintain audit trails for all system activities, ensuring any flagged activities can be investigated in line with data protection laws. * Employees are required to report suspicious activity to Rio Richardson. Other stakeholders can report to . * When necessary (i.e., if a potential conflict of interest is present), suspicious activities will be reported to the OCP Advisory Board, which will conduct a further investigation. ## Anti-Bribery and Corruption (ABC) Policy The Open Carbon Protocol adheres to the U.S. Foreign Corrupt Practices Act (FCPA) and has robust anti-bribery and corruption policies to mitigate potential issues within our business structure. Bribery is defined as the offering, promising, giving, accepting, or soliciting of any financial or other advantage - whether directly or indirectly - with the intent to improperly influence the actions or decisions of any person in a position of trust or authority. The OCP's prohibition on bribery covers all of the following: * Direct bribery: cash payments, gifts, or other items of value offered or received in exchange for a business advantage * Hospitality and entertainment: disproportionate or irregular hospitality, meals, travel, accommodation, or event tickets that could reasonably be construed as intended to influence a decision * Facilitation payments: unofficial payments made to expedite or secure routine actions, regardless of amount * Third-party bribery: bribery conducted through intermediaries, agents, contractors, or advisors acting on behalf of OCP or its participants * Supply chain bribery: improper payments or advantages offered or received within the project development, validation, verification, or credit issuance supply chain All employees, contractors, expert panelists, VVBs, dMRV providers, Advisory Board member and advisors are subject to this policy. #### Scope and Policy * If any suspicious activity is detected, the case will be investigated, and if found guilty, the person will be removed from the OCP permanently, and their account will be deactivated. If an expert panelist is found guilty of bribery, they will be removed from the panel altogether, and a thorough investigation will be conducted to ensure no other panelists are involved. The project developer's proposal will be suspended. * In the event there is reason to suspect board members are guilty of corruption or bribery, advisors and board members will be removed from their positions if it is known their decisions were influenced by the use of a bribe. * In order to ensure problematic practices are not taking place, the Open Carbon Protocol will implement measures to assess and reduce risk. The Open Carbon Protocol will conduct risk-based due diligence on business partners, projects, and transactions to identify and mitigate potential bribery. We commit to recording all financial transactions accurately in the OCP's records and books. All staff undergo anti-bribery and money laundering training to ensure everyone understands what to look out for and how to manage instances if they should come up. This will include case studies of bribery as they pertain to carbon credits and the OCP's procedures for reporting such instances. * Any interactions with government officials must adhere to the U.S. FCPA and adhere to strict ethical standards. The Foreign Corrupt Practices Act (FCPA) makes it unlawful for a person or company to offer, pay, or promise to pay for something of value to a foreign official in exchange for obtaining or retaining business. "Foreign official" is anyone acting on behalf of a government. A person or company may refer to anyone with authority acting on behalf of a company. #### **Mitigation and Training** * Our anti-bribery and corruption policy applies to all employees, contractors (including expert panelists, VVBs, and dMRV providers), Advisory Board members and advisors to the Open Carbon Protocol. * The Open Carbon Protocol prohibits bribery in any form, whether indirect or direct, in exchange for gifts to receive a business advantage in all business dealings worldwide. We are committed to transparency, integrity, and fair business practices. * Common sense should be used when deciding whether or not gifts are appropriate. Gifts are defined as anything of value to the receiver, such as merchandise, cash, tickets to events, travel, etc. If there is a question as to whether a gift is acceptable, it should be reported to and vetted by the Open Carbon Protocol Administration (). All suspicious activity will be reported to the OCP Advisory Board, who will discern necessary next steps. --- # Agent Instructions: Querying This Documentation If you need additional information that is not directly available in this page, you can query the documentation dynamically by asking a question. Perform an HTTP GET request on the current page URL with the `ask` query parameter: ``` GET https://open-carbon-protocol.gitbook.io/ocp-handbook/governance/know-your-business-kyb-anti-money-laundering-aml-anti-bribery-and-corruption-abc.md?ask= ``` The question should be specific, self-contained, and written in natural language. The response will contain a direct answer to the question and relevant excerpts and sources from the documentation. Use this mechanism when the answer is not explicitly present in the current page, you need clarification or additional context, or you want to retrieve related documentation sections.