1. Introduction

This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy outlines Escrowfy's commitment to preventing financial crime, including money laundering, terrorist financing, fraud, and other illicit activities on our platform. This policy establishes the framework for how we verify user identities, monitor transactions, and comply with applicable laws and regulations.

By using the Escrowfy platform, you agree to comply with this policy in addition to our Terms of Service.

2. Policy Objectives

The objectives of our AML & KYC Policy are to:

• Prevent the use of our platform for money laundering, terrorist financing, or other illegal activities
• Verify the identity of our users to ensure transparency and accountability
• Monitor transactions for suspicious activity
• Maintain appropriate records to assist with regulatory compliance
• Report suspicious activities to appropriate authorities when required
• Protect the integrity and reputation of our platform
• Comply with applicable laws and regulations

3. Know Your Customer (KYC) Requirements

3.1. Identity Verification Tiers

Escrowfy implements a risk-based, tiered approach to identity verification:

Tier 1: Basic Verification (All Users)

Required for basic account creation and small transactions:

• Email address verification
• Phone number verification
• Basic profile information (name, username)

Tier 2: Enhanced Verification

Required for higher transaction limits, selling privileges, or wallet withdrawals:

• All Tier 1 requirements
• Government-issued photo ID verification
• Proof of address (utility bill, bank statement, etc. issued within the last 3 months)
• Selfie with ID or video verification

Tier 3: Advanced Verification

Required for high-value transactions, business accounts, or when additional scrutiny is needed:

• All Tier 2 requirements
• Additional supporting documentation
• Source of funds declaration
• Business registration documents (if applicable)
• Beneficial ownership information (for business accounts)

3.2. Verification Process

Our verification process includes the following steps:

1. Submission: Users submit required documentation through our secure verification portal
2. Review: Our compliance team reviews the submitted documents
3. Verification: Documents are checked for authenticity and consistency
4. Additional Information: If needed, we may request additional documentation or clarification
5. Approval/Rejection: The verification request is either approved or rejected
6. Notification: Users are notified of the verification outcome

3.3. Re-verification Requirements

Escrowfy may require re-verification in the following circumstances:

• When significant changes are made to account information
• When suspicious activity is detected
• Periodically for high-risk users (every 1-2 years)
• When required by changes in applicable laws or regulations
• When verification documents expire

4. Transaction Monitoring

4.1. Monitoring Approach

Escrowfy monitors transactions to identify suspicious activities that may indicate money laundering, terrorist financing, or other financial crimes. Our monitoring includes:

• Automated systems to flag unusual transaction patterns
• Manual reviews of high-risk transactions
• Screening against sanctions and PEP (Politically Exposed Persons) lists
• Ongoing monitoring of user activity and behavior

4.2. Suspicious Activities

Activities that may be flagged as suspicious include, but are not limited to:

• Unusually large transactions relative to a user's normal activity
• Rapid succession of transactions with no apparent business purpose
• Transactions with no logical economic purpose or commercial rationale
• Transactions involving high-risk countries or regions
• Complex transaction patterns designed to obscure the true nature of the transaction
• Attempts to circumvent verification requirements
• Multiple accounts controlled by the same individual or group
• Unusual payment methods for the type of transaction
• Transactions involving sanctioned individuals or entities

4.3. Actions on Suspicious Activities

When suspicious activity is detected, Escrowfy may take one or more of the following actions:

• Place temporary holds on transactions pending investigation
• Request additional information or documentation from involved users
• Limit account functionality during investigation
• Close accounts engaged in prohibited activities
• File reports with appropriate regulatory or law enforcement authorities
• Freeze funds if required by law or court order

5. Prohibited Activities

The following activities are strictly prohibited on the Escrowfy platform:

• Money laundering or attempting to conceal the origins of illegally obtained money
• Terrorist financing or supporting terrorist organizations
• Fraudulent activities or scams
• Transactions involving proceeds of criminal activity
• Transactions with sanctioned individuals, entities, or countries
• Providing false or misleading information during the verification process
• Creating accounts on behalf of others without proper authorization
• Using the platform to facilitate illegal activities of any kind
• Structuring transactions to avoid reporting or compliance requirements

Engaging in these prohibited activities will result in immediate action, which may include account termination, fund freezing, and reporting to appropriate authorities.

6. Risk Assessment

6.1. User Risk Factors

Escrowfy assesses user risk based on various factors, including but not limited to:

• Geographic location and jurisdiction
• Transaction history and patterns
• Account age and activity level
• Types of products or services involved in transactions
• Payment methods used
• Connections to high-risk individuals or businesses
• PEP status
• Previous compliance issues or suspicious activities

6.2. Enhanced Due Diligence

Users identified as higher risk may be subject to Enhanced Due Diligence (EDD), which may include:

• More extensive documentation requirements
• More frequent re-verification
• Deeper investigation into sources of funds
• Stricter transaction limits or additional approvals
• More intensive ongoing monitoring

7. Record Keeping

Escrowfy maintains records of user identification, verification, and transactions in accordance with applicable laws and regulations. These records include:

• User identification and verification documents
• Transaction details and supporting documentation
• Records of suspicious activity reports
• Compliance reviews and investigations
• Communications related to AML/KYC matters

Records are typically maintained for a minimum of five years after the end of the business relationship or transaction, or as required by applicable laws.

8. Regulatory Compliance

Escrowfy is committed to complying with applicable AML/KYC laws and regulations in the jurisdictions where we operate. This includes, but is not limited to:

• Filing necessary reports with regulatory authorities
• Cooperating with legitimate law enforcement requests
• Updating our policies and procedures to reflect regulatory changes
• Conducting regular compliance training for our staff
• Performing periodic internal audits of our compliance program

9. User Privacy and Data Protection

While implementing our AML/KYC procedures, Escrowfy is committed to protecting user privacy and handling personal data responsibly. We ensure that:

• Personal data is collected only for legitimate compliance purposes
• Information is stored securely and accessed only by authorized personnel
• Data is retained only for as long as necessary or required by law
• User information is shared with third parties only when legally required or with user consent
• All data handling complies with applicable privacy laws and regulations

For more details on how we handle personal data, please refer to our Privacy Policy.

10. User Responsibilities

As a user of the Escrowfy platform, you have the following responsibilities under this policy:

• Provide accurate, truthful, and complete information during the verification process
• Update your information promptly if there are any changes
• Respond to requests for additional information or clarification in a timely manner
• Comply with all applicable laws related to money laundering, terrorist financing, and financial crimes
• Not use the platform for any illegal or prohibited activities
• Report any suspicious activities you observe on the platform

Failure to meet these responsibilities may result in limitations on your account functionality, suspension, or termination.

11. Changes to This Policy

Escrowfy reserves the right to modify this AML & KYC Policy at any time. Changes will be effective upon posting to the website. We will notify users of significant changes via email or platform notification. Your continued use of our platform after such changes constitutes acceptance of the modified policy.

12. Contact Us

If you have any questions about our AML & KYC Policy or need assistance with the verification process, please contact our compliance team:

Email: compliance@escrowfy.com

Or through our support ticket system available on our website.