AML & KYC Policy

This policy describes the controls BridgeEscrow applies to every account and escrow. It applies to all customers, both parties to every escrow, and all staff. It is reviewed at least once a year and whenever the law or our risk assessment changes.

Before a customer can sign an Escrow Agreement or deposit, we collect and verify:

• full legal name, date of birth, nationality, and country of residence;
• residential address and phone number;
• a clear image of a valid passport photo page, or another government-issued identity document we accept;
• for legal entities: registration documents, registered address, directors, and beneficial owners holding 25% or more.

Both parties to an escrow are verified. Uploading a document does not by itself approve an account; a review is always performed.

We apply additional checks where risk is higher, for example:

• large trade values or a pattern of trades inconsistent with the customer’s profile;
• politically exposed persons, their family members, and close associates;
• connections to high-risk jurisdictions identified by the FATF or by our risk assessment;
• deposits from addresses linked to mixers, darknet markets, or other high-risk sources.

Enhanced checks may include source-of-funds and source-of-wealth evidence, additional identity documents, or a video verification call.

Customers are screened at onboarding and on an ongoing basis against applicable sanctions and watch lists, including those maintained by the United Nations, the European Union, the United Kingdom, and the United States (OFAC). A confirmed match leads to the account being blocked and any affected assets being frozen and reported as the law requires.

Deposit sources and payout addresses are assessed for exposure to sanctioned entities and illicit activity. We may delay crediting a deposit or sending a release while an address is reviewed, and we may refuse to send assets to an address we consider high risk.

We monitor escrows and account activity for unusual patterns, such as repeated cancellations after deposit, structuring of amounts, or mismatches between the parties’ profiles and the trade. We may ask customers to refresh their information or documents at any time.

Where we know or suspect that funds are the proceeds of crime or linked to terrorist financing, we report it to the competent financial-intelligence unit. The law may prohibit us from telling the customer that a report has been made.

We may refuse to open an account or escrow, freeze assets, withhold a release, or close an account where checks cannot be completed, information is false or incomplete, or we suspect prohibited activity. Assets frozen on legal grounds are held until we are lawfully permitted to release or return them.

We do not serve customers resident in, or nationals of, countries subject to comprehensive sanctions, or customers acting for persons in those countries. We also do not accept escrows connected to:

• illegal goods or services, fraud, or scams;
• unlicensed gambling, money transmission, or securities offerings;
• trading on behalf of undisclosed third parties;
• attempts to obscure the origin of funds, including the use of mixers or tumblers.

Identity records, verification results, Escrow Agreements, signatures, transaction records, and review notes are kept for at least 7 years after the end of the customer relationship or the closing of the escrow, or longer where the law requires.

A designated compliance officer oversees this policy. Settlements and refunds need approval from two different staff members, and identity decisions are logged with the reviewer’s name. Staff receive anti-money-laundering training when they join and at least once a year after that.

Questions about this policy can be sent to info@bridgescrow.com.