1. Introduction

Escrowly.com ("Escrowly," "we," "us," or "our") is a crypto only escrow platform committed to maintaining full regulatory compliance with financial authorities and legal frameworks worldwide. As Money Services Business (MSB) registered with FinCEN, we adhere to strict Anti-Money Laundering (AML) and Know Your Customer (KYC) regulations to ensure the highest standards of security and legal compliance.

This document outlines our regulatory obligations, compliance measures, and risk management policies that govern our operations.

2. Regulatory Compliance Framework

Escrowly is committed to providing a secure, legally compliant, and transparent crypto escrow service. We continuously enhance our compliance measures to align with global regulations and industry best practices.

Escrowly operates under full compliance with international financial regulations, which include all applicable standards.

1. As an MSB under FinCEN regulation, Escrowly meets all needs of federal financial reporting in addition to Anti-Money Laundering requirements
2. The company implements vigorous AML/KYC policies through the Bank Secrecy Act to avoid financial crimes
3. The company adheres to OFAC screening procedures which help detect transactions involving sanctioned people and organizations
4. The company upholds global AML/KYC standards through its commitment to FATF (Financial Action Task Force) anti-money laundering and anti-terrorist financing recommendations

3. Money Services Business (MSB) Registration

The business entity Escrowly LLC is currently working on FinCEN Money Services Business (MSB) registration at their United States headquarters. The registration process protects Escrowly from violations of federal cryptocurrency laws and aids in fraud prevention and reporting requirements.

D-U-N-S® Number: 136876298

4. Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy

Escrowly protects itself from financial crime risks through an advanced AML/KYC compliance system that follows these steps:

4.1 Customer Identification Program (CIP)

• a. Users must conduct identity verification prior to beginning any escrow process. This requirement applies to everyone at Escrowly.
• b. Escrowly requires verification through government IDs and proof of residence in addition to additional requested documentation from users during the signup process.
• c. The company performs continuous transaction surveillance to detect abnormal behaviors.

4.2 Transaction Monitoring & Reporting

• a. The system has automated tools that identify irregular deals or transactions showing high risk.
• b. Under the policy, we must file suspicious activity reports (SARs) to FinCEN whenever it becomes necessary.
• c. Blockchain analytics technologies provide real-time tracking functionality to identify and prevent fraudulent transactions.

4.3 Sanctions & Restricted Users Screening

• a. Escrowly evaluates users and transactions through checks against United States Treasury Office of Foreign Assets Control (OFAC) sanctions lists, together with international watch list criteria.
• b. Our platform denies access to both high-risk jurisdictions and politically exposed persons (PEPs).

5. Licensing & Legal Considerations

Escrowly.com serves exclusively as a crypto escrow platform since it deals with cryptocurrency escrow transactions between its users. We DO NOT offer any service involving fiat currencies or conventional banking operations or payment processing. The platform handles only cryptocurrency asset escrow operations that connect users in their transactions.

Compliance with state-specific money transmission laws were required.

6. Data Security & Privacy Compliance

Our user information protection relies on strict data security protocols which follow multiple privacy regulations including:

• a. GDPR (General Data Protection Regulation): User data protection and privacy for EU-based users.
• b. CCPA: California residents must provide clear information about data collection as well as user rights.
• c. Blockchain Privacy Considerations: Ensuring minimal personal data exposure on public blockchain ledgers.

7. Risk Management & Internal Controls

The service implements risk-based compliance rules to protect the business from financial offenses and maintain organizational integrity.

• Regular assessment of regulatory compliance effectiveness.
• Employee Training Programs conduct regular AML/KYC compliance training sessions for the entire staff workforce.
• The company maintains firm procedures for non-compliant situations, with both user account deactivation and full support to law enforcement teams.

8. Regulatory Reporting & Cooperation

Escrowly works with international financial organizations through these joint efforts.

• The company submits necessary FinCEN and AML compliance reports according to the regulatory requirements.
• Escrowly assists law enforcement agencies through its cooperation during investigations of financial crime and fraud cases.
• Escrowly maintains total transparency in all reporting activities with established regulatory organizations.

9. Contact & Compliance Officer Information

For any regulatory compliance inquiries, You may contact us via online form or via regular mail at.

Escrowly LLC

701 Tillery Street Unit 12 STE 2962 Austin, TX 78702, USA