This is true, but it's a weird way to frame it. Yes, absolutely: carbon-sensitive regulation changes the market pricing such that less polluting activities and means of production are "worth more". So if you have some, you win. If you were planning on having some in the future ("were going to do anyway"), you likewise get a windfall.
And thats... good? It's not perfect. But it produces the result we want.
IMHO the much bigger problem with offset regulation is that it's likely to be nearly impossible to actually measure[1] and we'll be dealing with cheating and fraud for decades. But the incentives seem fine to me.
[1] Vs. a carbon tax which is pure simplicity: $xxx per ton of carbon (for extra credit: a floating price based on a dynamic bid-based sequestration market) pulled out of nonrenewable sources, paid by the extractor at the time of initial sale, and let the market sort out how to allocate the overhead.