Escrowlyst
Compliance

AML & KYC Policy

How Escrowlyst meets anti-money-laundering obligations while keeping smaller deals frictionless.

Last updated · January 1, 2026

Why we run AML/KYC at all

Escrowlyst handles client funds and operates a financial-style service across borders. Even where local law does not compel us, we voluntarily adopt FATF-aligned controls to keep the platform safe for honest traders and unattractive to bad actors.

Risk-based approach

We tier KYC by transaction size and risk signals. Most deals settle with verified Telegram identity alone. Larger or flagged deals trigger a lightweight identity review handled privately by our compliance officer inside the same thread.

Verification thresholds

  • < $2,000 USD equivalent: Verified Telegram identity only.
  • $2,000 – $10,000: Government photo ID + selfie.
  • $10,000 – $25,000: ID, selfie, and proof of address (utility bill or bank statement < 90 days old).
  • > $25,000: All of the above, plus a short narrative explaining the source of funds and corroborating documents.

Risk signals that escalate KYC

  • Counterparty is in a FATF grey- or black-list jurisdiction.
  • Funds arrive from a mixer, sanctioned exchange, or a freshly-created wallet with no history.
  • Either party refuses to confirm their stated identity on Telegram.
  • Deal pattern matches known scam typologies (e.g. urgency, foreign asset, off-platform payment).

Sanctions screening

Every counterparty is screened against major sanctions lists (OFAC, UN, EU, HMT, OSFI) before funds clear into the vault. Hits are escalated to the compliance officer and may halt the deal. We do not notify a party that their counterparty has been flagged — we simply refuse to proceed.

Source-of-funds & source-of-wealth

For high-value or high-risk deals, we may request short, plain-English explanations of where the money or the asset came from. Acceptable evidence includes invoices, payroll stubs, exchange withdrawal receipts, sale agreements, or cap-table snapshots. We do not need bank balances or unrelated history.

Reporting

Where a deal triggers a regulatory reporting obligation, Escrowlyst will file the appropriate suspicious activity report and may suspend the transaction without prior notice. By using Escrowlyst you acknowledge that we may be legally barred from telling you whether a report has been filed.

Recordkeeping

  • KYC files are retained for 5 years after the last deal you participate in, in line with FATF Recommendation 11.
  • Deal threads and on-chain records are retained for 7 years for tax and audit purposes.
  • Records are encrypted at rest with AES-256 and only accessible to compliance staff.

Your rights

You may request a copy of the KYC data we hold about you at any time. Outside the retention windows above, you may request erasure. See our Privacy Policy for the full picture.