Today, Verra released a legal due diligence questionnaire for users of the Verra Registry that create, market, or transact in related instruments.

A related instrument is a connected, subset, linked, or other related product that is legally distinct from a unit issued by Verra, such as a Verified Carbon Unit (“VCU”), and has such a unit as its underlying. For avoidance of doubt, this definition includes cryptocurrency instruments such as tokens or coins.

The questionnaire asks a series of questions about the user’s know-your-client, anti-money-laundering, anti-terrorist-financing, and anti-bribery-and-corruption policies, as well as its financial and tax situation. Additional questions apply to users who create, market, or transact in related instruments for purposes other than offsetting their own emissions.

The Verra Registry Terms of Use, sections 1.9 to 1.11, stipulate that no user of the Verra Registry may create, market, or transact in related instruments without the express written consent of Verra, to be granted in Verra’s sole and absolute discretion.

Upon completion of the legal due diligence questionnaire, Verra will analyze the results and may request additional information. If Verra determines, in its sole and absolute discretion, that the user has fulfilled the legal due diligence requirements, it will proceed with a commercial assessment of the proposed arrangement followed by the negotiation of a bilateral agreement between Verra and the user.

Questions about related instruments, including the questionnaire, may be directed to