AML, Counter-Terrorist Financing, and Sanctions Policy Summary
EscrowSign maintains a risk-based programme to prevent money laundering, terrorist financing, sanctions evasion, and other financial crime. This is a public summary only. Specific thresholds and detection methods are not disclosed, as disclosure would assist those attempting to evade controls.
Risk-based verification
All users are subject to identity verification. The level of verification required depends on jurisdiction, transaction value, asset category, and risk indicators. Higher-risk users and transactions require enhanced due diligence.
Beneficial ownership
Business users must disclose all directors, authorised representatives, and ultimate beneficial owners above applicable thresholds.
Transaction monitoring
Transactions are monitored for indicators of financial crime including unusual value, structure, jurisdiction, asset type, and payment patterns.
Sanctions screening
All users, counterparties, businesses, and transactions are screened against applicable sanctions lists. Transactions involving sanctioned persons, entities, jurisdictions, or sectors are rejected.
Wallet and blockchain screening
Where crypto assets are involved, wallet addresses are screened using an approved blockchain-risk provider.
Source-of-funds and source-of-wealth
We may request evidence of the source of funds or wealth for high-value, complex, or high-risk transactions. Failure to provide this information may result in suspension of the transaction.
Recordkeeping
Transaction records, identity documents, and compliance decisions are retained for the periods required by applicable law.
Reporting obligations
Where required by law, EscrowSign or its licensed partners will report suspicious activity to relevant financial intelligence units or competent authorities. We are not permitted to disclose whether a report has been made (“tipping off” restrictions).
Account restrictions
Accounts and transactions may be restricted, suspended, frozen, or closed at any time where required for compliance or risk management purposes.