Introduction to our Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) Policy
While the core of our activity – the creation and sale of carbon credits – is not considered a traditional financial service in itself, we recognize that the dynamic carbon market is a source of significant financial flows. Its complex, international transactions can pose an elevated risk from a money laundering perspective.
We are committed to ensuring that our non-profit organization sets an example not only in environmental integrity but also in financial integrity. This policy demonstrates that we take the transparency of our transactions and responsible financial management seriously, thereby strengthening the trust of our partners and supporters.
Anti-Money Laundering and Counter-Terrorism Financing Policy
OurOffset Nonprofit LLC
1. Purpose
This Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Policy establishes the framework under which OurOffset Nonprofit LLC ensures compliance with all applicable laws and regulations related to the prevention of money laundering and the financing of terrorism.
The purpose of this Policy is to maintain transparency, integrity, and accountability in all financial and operational activities of the organization, in line with EU Directive (EU) 2018/843 (AMLD5) and the Hungarian Act LIII of 2017.
2. Scope
This Policy applies to all activities, employees, volunteers, contractors, and financial transactions of OurOffset Nonprofit LLC, including relationships with donors, beneficiaries, and partner organizations.
3. Principles
Transparency:
All financial operations of the organization are fully transparent and traceable.
Lawfulness:
OurOffset Nonprofit LLC conducts only legitimate activities and accepts funding exclusively from lawful and verifiable sources.
Accountability:
The organization maintains accurate financial records and ensures compliance with all reporting obligations.
Zero tolerance for illicit funds:
Donations, grants, or contributions from unknown or suspicious sources are strictly prohibited.
Data protection:
All identification and verification procedures comply with data protection legislation (GDPR).
4. Roles and Responsibilities
Executive Director / Compliance Officer:
The Executive Director (or appointed Compliance Officer) is responsible for implementing and monitoring this Policy and ensuring that all relevant persons are aware of their obligations under AML/CTF laws.
Employees and Partners:
All personnel must immediately report any suspicion of illegal activity or unusual transactions to the Executive Director, who will assess and, if necessary, notify the competent authority.
5. Identification and Verification (Know Your Partner / KYP)
OurOffset Nonprofit LLC performs due diligence on all partners, donors, and beneficiaries, proportionate to the level of financial and reputational risk.
This includes, where relevant:
verifying the identity and legal status of the entity or individual;
assessing the origin of funds;
confirming that no partner appears on sanctions lists (e.g. EU, UN, OFAC).
6. Record Keeping
The organization retains all documentation related to financial transactions, donations, and partner identification for a minimum of eight (8) years, in accordance with applicable legislation.
These records must be securely stored and made available to competent authorities upon lawful request.
7. Suspicious Activity Reporting
If the organization identifies any transaction or activity that may indicate money laundering or terrorist financing, it must be reported immediately to the Hungarian Financial Intelligence Unit (FIU Hungary / NAV Pénzmosás Elleni Információs Iroda).
The Executive Director ensures that all such reports are handled confidentially and in compliance with legal obligations.
8. Training and Awareness
OurOffset Nonprofit LLC ensures that its management and relevant staff members are familiar with the AML/CTF requirements and receive periodic updates or guidance as necessary.
9. Review and Updates
This Policy is reviewed annually or whenever significant regulatory changes occur.
The Executive Director is responsible for ensuring that the Policy remains compliant with current laws and best practices.
10. Final Provisions
This Policy was approved by the management of OurOffset Nonprofit LLC and is effective as of [Date].
All members, employees, and partners are required to adhere to its provisions.
Approved by:
OurOffset Nonprofit LLC
Alkotmány u. 69. 1. em. 8. 9600 Sárvár Hungary
Tax ID: HU26796123
EU ID: HUOCCSZ. 18-09-114028
Update date: 20 October 2025
