Compliance
EscrowSign operates a risk-based compliance programme covering identity verification, transaction monitoring, sanctions screening, and anti-money-laundering controls.
Asset Freeze & Investigation Policy
EscrowSign is required by law and its own risk framework to freeze funds held in escrow when a transaction displays indicators of financial crime, fraud, sanctions exposure, legal dispute, or any other risk that warrants investigation. By using the platform, all parties acknowledge and agree to the following.
Grounds for a freeze
Funds may be frozen when the platform identifies — or is notified of — indicators including but not limited to: suspected fraud or deception, sanctions or PEP exposure, court order or regulatory direction, asset title dispute, suspicious transaction patterns, unresolved source-of-funds concerns, or any other circumstance that a reasonable compliance programme would require to investigate.
Unilateral right to act
EscrowSign may impose a freeze without prior notice to either party and without the consent of either party. The platform is not required to disclose the specific reason for a freeze where disclosure would prejudice a legal investigation, regulatory process, or law enforcement action.
Duration of the freeze
A frozen transaction will remain suspended until the investigation is fully concluded and one or more of the following conditions is met: (a) the platform determines that no further risk exists and all compliance obligations are satisfied; (b) a court of competent jurisdiction issues an order directing release or disposal of the funds; (c) the relevant regulatory authority confirms that the matter has been resolved; or (d) applicable legal holding periods have expired.
Cooperation required
Both parties must cooperate fully with any investigation. This includes providing identity documents, source-of-funds evidence, asset title documentation, correspondence, and any other information reasonably requested. Refusal or delay to cooperate may be treated as an aggravating factor and may extend the freeze indefinitely until compliance requirements are met.
Disposal of funds
Where an investigation results in a legal obligation to report, restrain, or confiscate funds, EscrowSign will comply with applicable law. In such cases, funds may be transferred to a government authority, regulatory body, or law enforcement agency, and neither party may make a claim against EscrowSign for such transfer.
No liability during freeze
EscrowSign accepts no liability for any loss — including consequential, financial, commercial, or reputational loss — arising from a compliant freeze. The platform acts in good faith in accordance with its legal and regulatory obligations. A freeze does not constitute a finding of wrongdoing by either party.
Important: If your transaction has been frozen, contact our compliance team through your authenticated account dashboard. Do not attempt to initiate a replacement transaction — this may constitute an attempt to circumvent a freeze and will be reported to the relevant authorities.
Identity and business verification
Every user must verify their identity before transacting. Business users must disclose directors, authorised representatives, and ultimate beneficial owners. Verification decisions consider government ID, liveness, sanctions, PEP status, and adverse media.
Transaction monitoring
All transactions are monitored for indicators of financial crime, sanctions exposure, and prohibited activity. High-value, cross-border, or unusual transactions may require additional review.
Sanctions screening
Users, counterparties, businesses, and where applicable crypto wallets are screened against applicable sanctions lists. Transactions involving sanctioned persons, entities, or jurisdictions are rejected.
Source of funds
Source-of-funds information may be requested for high-value transactions or where required by applicable rules. Failure to provide this information may result in the transaction being suspended or rejected.
Reporting obligations
Where required by law, EscrowSign or its licensed partners may report transactions to relevant financial intelligence units or authorities. We do not disclose whether a report has been made.
Record retention
Financial, AML, legal, fraud, and tax records are retained for the periods required by applicable law, which may extend after account closure.
For the full compliance framework, see our AML/CTF and Sanctions Policy. Specific thresholds and detection methods are not disclosed.