Prohibited and Restricted Use Policy
Effective date: [To be confirmed]Version: Draft 1.0
Use of the EscrowSign platform is prohibited for the transaction types and purposes listed below. This list is not exhaustive. Where a transaction type is not listed as permitted, it should be treated as prohibited unless confirmed otherwise.
Attempting to transact in a prohibited category may result in immediate account suspension, transaction cancellation, loss of fees, and reporting to relevant authorities. Some violations are required by law to be reported.
1. Absolutely prohibited — no exceptions
- Weapons, firearms, ammunition, and military equipment (regardless of legal status in any jurisdiction)
- Explosives, dual-use goods subject to export controls, and items on applicable control lists
- Illegal drugs, narcotics, controlled substances, and paraphernalia
- Child sexual abuse material (CSAM), child exploitation material, or any illegal sexual content
- Human trafficking, forced labour, modern slavery, or services facilitating same
- Stolen property, counterfeit goods, or goods infringing third-party intellectual property rights
- Ransomware, malware, exploits, hacking tools, and cyberweapons
- Money laundering, terrorist financing, proliferation financing, or sanctions evasion
- Bribery, corruption, fraudulent contracts, or transactions with no genuine commercial purpose
- Pyramid schemes, Ponzi schemes, or fraudulent investment programmes
- Transactions with any sanctioned person, entity, jurisdiction, or sector
- Unregistered securities offerings or regulated financial instruments without applicable licence
- Transactions violating applicable export controls or dual-use regulations
- Any transaction that is illegal in the applicable jurisdiction(s)
2. Regulated — requires licensed partner and legal review
- Real estate and land transactions (require licensed title and conveyancing services)
- Motor vehicles and vessels (require title/registry verification)
- Crypto-asset custody and exchange services (require applicable VASP licence)
- Business acquisitions and M&A transactions above applicable thresholds
- Pharmaceutical or medical device transactions
- Alcohol, tobacco, or age-restricted goods (require regulatory compliance in each jurisdiction)
- Adult content or services (where legal, requires enhanced age and identity verification)
- Gambling-related businesses, licences, or assets
- Financial services licences, regulatory approvals, or regulated assets
- Healthcare businesses, patient lists, or medical records
These transactions are not available unless specifically enabled for your account following applicable review and partner activation.
3. Restricted — requires enhanced due diligence
- High-value goods including fine art, jewellery, precious metals, and collectibles above applicable thresholds
- Transactions involving politically exposed persons (PEPs) or their immediate family members
- Cross-border transactions involving high-risk jurisdictions as defined by applicable watchlists
- Transactions where source-of-funds or source-of-wealth evidence cannot be provided
- Shell company or nominee structures where beneficial ownership cannot be verified
- Cash-equivalent funding methods where permitted (subject to additional controls)
- Professional services that require a licensed practitioner in the applicable jurisdiction
4. Prohibited conduct
- Providing false or misleading information during registration, verification, or transactions
- Using another person’s identity or acting as a front for an undisclosed third party
- Structuring transactions to avoid thresholds or verification requirements
- Attempting to coerce, threaten, or defraud a counterparty
- Conducting negotiations or sharing payment details outside the Platform
- Using automated scripts, bots, or scraping tools without written authorisation
- Attempting to reverse-engineer, tamper with, or probe the Platform’s security systems
- Creating multiple accounts to circumvent restrictions or verification requirements
- Using the Platform to facilitate disputes, claims, or proceedings that are fraudulent
- Introducing malware or harmful code through document uploads or messages
5. Consequences of violation
Violations may result in any or all of the following at our discretion:
- Immediate suspension or permanent closure of your account
- Freezing of the transaction and associated funds pending investigation
- Forfeiture of applicable platform fees
- Referral to law enforcement, financial intelligence units, or regulatory authorities
- Civil or criminal liability under applicable law
6. Reporting
If you believe a transaction on the Platform involves prohibited activity, report it immediately through the in-Platform report function or through the official contact page. We take all reports seriously and investigate in accordance with our compliance obligations.