Does a small Verra project developer need anti-bribery and money laundering policies?
These sections have no size exemption. VCS Standard v5.0 bars corruption, requires due diligence on parties in the project and policies to prevent, detect and fix it, and requires the same for money laundering. Workers must be told and, where policies exist, trained and asked for an annual written acknowledgement.
Corruption
- The project proponent must not engage in any form of corruption: bribery, embezzlement, fraud, abuse of power or influence peddling. It must take measures so project workers do not either.
- It must support the parties working under its direction in following anti-bribery and anti-corruption laws.
- It must carry out due diligence on parties involved in implementation, including legal counsel and financial and management service firms.
- It must have policies and procedures aligned with best practice to prevent, detect and remediate corruption related to the project.
Money laundering
- Project financing must not come from the proceeds of crime or otherwise break an anti-money laundering law, including the Financial Action Task Force recommendations.
- The proponent must not violate or help violate money laundering laws, and must take measures so workers do not either.
- Policies must be in place to prevent, detect and monitor transactions that could help money laundering.
- Warning signals must be dealt with without delay.
Telling and training people
Project workers, consultants and advisors must be told these requirements. Where policies are put in place to meet them, workers must get access to the policies and training, and the proponent must obtain an annual acknowledgement of compliance from each project worker.
Official requests
To the extent the law permits, a subpoena, summons or other official request about the project must be notified to Verra within five calendar days.
What a small developer can do
The text above has no size exemption, so a short policy, a counterparty check on each major supplier, a signed acknowledgement from each worker and a log of payments that match the project budget are a reasonable base. Confirm what is enough with your verifier.
What Senseible does here
Senseible does not write policies or run due diligence. It keeps dated invoices, each with a fingerprint, so the trail of what was bought and when is easy to show.
Sources: Verra, VCS Standard v5.0 (16 December 2025), Sections 3.18.28 to 3.18.37
Last reviewed 2026-11-04. Section numbers are from VCS Standard v5.0 (16 December 2025); re-check them when Verra publishes a new version.