The updated TOU establishes guidelines for the responsible use of the Registry, including by:
- Requiring accountholders who conduct specified business activities, such as holding VCUs on behalf of third parties, to represent that they hold all necessary regulatory approvals and have conducted Know-Your-Customer checks;
- Requiring accountholders to seek Verra’s written consent if creating, marketing, or transacting in “related instruments”, such as derivative products backed by VCUs;
- Prohibiting account-holders from holding or brokering VCUs on behalf of individuals (i.e., natural persons) for investment purposes, though personal offsetting services would still be permitted;
- Formalizing Verra’s commitment to act as a “reasonable and prudent operator” of the Registry.