AML / KYC Policy

1. Purpose

EscrowPeer is committed to preventing money laundering, terrorist financing, and other financial crimes. This policy describes our approach to identifying users, monitoring transactions, and reporting suspicious activity. It applies to all users, administrators, and staff.

2. KYC Requirements

All users wishing to trade on the Platform must complete identity verification before initiating or accepting any trade. KYC verification requires:

• Government-issued photo ID — passport, national identity card, or driver's licence (front and back where applicable)
• Liveness selfie — a clear photo of you holding your ID document and a handwritten note with the platform name and current date
• Proof of address — utility bill, bank statement, or official letter dated within the last 3 months showing your name and residential address

All documents must be original, unedited, and clearly legible. We reserve the right to request additional documentation for enhanced due diligence (EDD) where warranted by risk factors.

3. Verification Process

KYC submissions are reviewed manually by our compliance team within 24 hours. We may approve, reject, or request additional information. Users whose KYC is rejected will be notified with reasons where legally permissible and may resubmit with corrected documents once.

4. Sanctions Screening

We screen all users against applicable international sanctions lists including those maintained by the UN Security Council, OFAC, EU, and HM Treasury. Users appearing on sanctions lists will not be permitted to trade and their accounts will be suspended immediately. We will cooperate fully with relevant authorities.

5. Transaction Monitoring

We monitor trading activity for patterns consistent with money laundering. Risk factors include but are not limited to:

• Unusually large transactions inconsistent with user profile
• Rapid sequential trades with no apparent commercial purpose
• Payments from or to high-risk jurisdictions
• Structured transactions designed to avoid reporting thresholds
• Payments associated with known fraud patterns
• Mismatched payment references or payer names

6. Suspicious Activity Reporting

Where we identify suspicious activity, we are required to make a suspicious activity report (SAR) to the relevant financial intelligence unit in our jurisdiction. We will not tip off the subject of such a report. We cooperate fully with all lawful orders from law enforcement and regulatory authorities.

7. Record Keeping

We retain KYC documents, trade records, and transaction data for a minimum of 5 years following the end of a business relationship, in compliance with applicable AML regulations. Records are stored securely with access limited to authorised compliance personnel.

8. Politically Exposed Persons (PEPs)

Users identified as Politically Exposed Persons (current or former government officials, their family members, or close associates) are subject to enhanced due diligence. This may include additional documentation, source of funds declaration, and senior management approval before account activation.

9. Prohibited Use Cases

The Platform must not be used to:

• Launder proceeds of crime, including fraud, theft, or tax evasion
• Finance terrorism or proliferation of weapons
• Evade sanctions or circumvent financial regulations
• Process payments on behalf of unlicensed money service businesses

Violation of these prohibitions results in immediate account suspension and will be reported to relevant authorities.

10. User Obligations

By using the Platform, you confirm that:

• All funds you trade are from legitimate sources
• You are acting on your own behalf, not as an agent for an undisclosed third party
• You will cooperate with any due diligence requests
• You will not knowingly accept payments from fraud victims

11. Contact

Compliance enquiries should be submitted via the support ticket system within your account. We cannot discuss ongoing investigations or SAR submissions for legal reasons.