AML & KYC Policy

1. Introduction

This AML & KYC Policy outlines the standards, procedures, and controls implemented by Escrowise.io ("the Company") to prevent and detect money laundering, terrorist financing, fraud, and other illicit financial activities. As an escrow services provider, Escrowise.io is committed to ensuring full compliance with all applicable laws and regulations relating to financial crime prevention, including but not limited to AML/CFT (Counter-Financing of Terrorism) requirements in the jurisdictions in which it operates. Escrowise.io maintains a risk-based approach to customer onboarding, transaction monitoring, and reporting.

2. Scope

This policy applies to:

• All Escrowise.io employees, contractors, and representatives
• All customers (individuals, sole proprietors, legal entities, and authorized representatives)
• All escrow transactions processed through the platform

3. Objectives

The objectives of this policy are to:

1. Prevent Escrowise.io from being used for money laundering, terrorist financing, fraud, corruption, or sanctions evasion.
2. Ensure that Escrowise.io identifies and verifies the identity of all customers before providing services.
3. Maintain appropriate risk-based monitoring of customer transactions.
4. Ensure timely reporting of suspicious activities to relevant authorities.
5. Maintain robust internal training, auditing, and compliance systems.

4. Regulatory Framework

Escrowise.io complies with all applicable AML/CFT regulations, including (examples—modify as appropriate):

• The Bank Secrecy Act (BSA)
• The USA PATRIOT Act
• FATF (Financial Action Task Force) Recommendations
• EU AML Directives (AMLD5/6)
• OFAC and UN Sanctions Lists
• Applicable local/national AML/CFT laws

5. Roles and Responsibilities

6. Customer Due Diligence (CDD)

Escrowise.io performs CDD before establishing a business relationship or processing escrow transactions.

7. Enhanced Due Diligence (EDD)

EDD is conducted for higher-risk customers, including but not limited to:

• Politically Exposed Persons (PEPs)
• Customers from high-risk jurisdictions
• Complex corporate structures
• Unusually large or frequent escrow transactions
• Cryptocurrency-related transactions (if applicable)

EDD may include:

• Additional identity verification
• Source of funds/wealth documentation
• Adverse media checks
• Ongoing monitoring and periodic reviews

8. Transaction Monitoring

Escrowise.io employs automated and manual monitoring systems designed to detect unusual or suspicious activity.

9. Sanctions Screening

Escrowise.io screens all customers against:

• OFAC lists
• UN sanctions lists
• EU sanctions lists
• Local regulatory sanctions lists

Customers or transactions matching sanctions data are immediately blocked, reviewed, and escalated to the AMLCO.

10. Record Keeping

Escrowise.io retains all AML/KYC documentation for at least 5–7 years (or as required by local regulations), including:

• Customer identification records
• Transaction details
• Communications and investigation notes
• SARs/STRs submitted

Records must be easily accessible for regulatory inspection.

11. Reporting Suspicious Activity

Escrowise.io complies with mandatory reporting requirements. The AMLCO is responsible for submitting:

• SARs/STRs
• Threshold transaction reports
• Compliance audit reports

Staff must not inform customers of any suspicious activity investigation ("tipping off").

12. Training Program

All employees must complete annual AML/KYC training covering:

• Money laundering and terrorist financing risks
• Escrow-specific fraud risks
• Customer identification processes
• Recognizing and reporting suspicious activities
• Data protection and privacy obligations

13. Data Protection and Privacy

Escrowise.io ensures that all customer data collected for KYC/AML purposes is processed in accordance with:

• GDPR (EU)
• CCPA (California)
• Other applicable privacy regulations

Customer information is used solely for compliance and service-provision purposes and is protected using industry-standard security measures.

14. Independent Audit & Review

Escrowise.io conducts periodic independent reviews to assess:

• Effectiveness of AML/KYC controls
• Staff compliance
• System capabilities
• Policy adequacy

Recommendations from audits must be implemented promptly.

15. Policy Violations

Failure to follow this policy may result in:

• Disciplinary action
• Termination of employment
• Reporting to regulatory authorities

16. Policy Updates

This policy is reviewed at least annually or upon:

• Changes in regulatory requirements
• Significant operational changes
• Identified deficiencies

Conclusion

Escrowise.io is committed to maintaining the highest standards of AML/KYC compliance. By implementing robust controls and maintaining a culture of compliance, the Company protects its customers, its reputation, and the integrity of the financial system.