Anti-Money Laundering Policy
Escora is committed to preventing money laundering, terrorist financing, and other financial crimes. This Anti-Money Laundering (AML) Policy outlines our approach to detecting, preventing, and reporting suspicious activities on our platform.
01Purpose and Scope
Escora is committed to preventing money laundering, terrorist financing, and other financial crimes. This policy applies to all users of Escora's escrow payment platform and reflects our compliance with Nigerian anti-money laundering laws, including the Money Laundering (Prohibition) Act and guidelines from the Central Bank of Nigeria and the Nigerian Financial Intelligence Unit. Money laundering is the process of making illegally obtained money appear legitimate. Terrorist financing involves providing financial support to terrorist organizations. Escora has zero tolerance for either and actively works to prevent our platform from being used for these purposes.
02Know Your Customer
2.1Customer Identification
We verify the identity of every user through a tiered verification system.
Tier 1: WhatsApp number and legal name. Limit: up to ₦100,000 per transaction.
Tier 2: Tier 1 plus National Identification Number (NIN), verified against official government databases. Limit: up to ₦500,000 per transaction.
Tier 3: Tier 2 plus Bank Verification Number (BVN), verified through authorized verification services. Limit: up to ₦1,000,000 per transaction.
2.2Ongoing Monitoring
We continuously monitor accounts and transactions for changes in behavior, significant increases in transaction volume or frequency, and other activity that may indicate money laundering. Users may be asked to update their KYC information periodically or when suspicious activity is detected.
03Transaction Limits and Monitoring
3.1Transaction Limits
To prevent large scale money laundering, we enforce the following limits:
Transactions approaching these limits are subject to enhanced review, and users transacting at consistently high volumes may be asked for additional documentation, such as business registration or proof of income.
Maximum transaction amount: ₦1,000,000 per transaction.
Daily transaction limit: ₦3,000,000 across all transactions.
Monthly transaction limit: ₦10,000,000 across all transactions.
3.2Suspicious Activity Indicators
We actively monitor for patterns that may indicate money laundering, including:
Flagged transactions may be automatically held for manual review, and our compliance team investigates flagged activity promptly.
Unusually frequent transactions, including rapid succession within short time periods.
Repeated transactions between the same buyer and seller, or multiple accounts transacting with each other in a way that resembles circular trading rather than genuine commerce.
Unusually large or round transaction amounts, vague item descriptions, or activity inconsistent with a user's profile or history.
Reluctance to provide KYC information, false documentation, or attempts to structure transactions to avoid limits or detection.
04Customer Due Diligence
We assess the money laundering risk of each user based on transaction patterns, verification tier, and other relevant factors. Higher risk users are subject to enhanced monitoring and verification. We continuously review account activity to ensure it remains consistent with a user's legitimate business or personal needs, and significant changes in transaction patterns may trigger additional review or require updated KYC information.
05Prohibited Items and Activities
5.1Prohibited Items
Escora cannot be used to transact:
Illegal drugs, controlled substances, or drug paraphernalia.
Weapons, firearms, ammunition, or explosives.
Stolen goods or items that infringe intellectual property rights.
Counterfeit products, fake documents, or fraudulent items.
Adult content, escort services, or sexually explicit material.
Live animals or endangered species.
Human organs, body parts, or biological material.
Gambling services, pyramid schemes, or multi-level marketing.
Hacked accounts, stolen data, or unauthorized access credentials.
Tobacco, cigarettes, vapes, or related products.
Any item that violates Nigerian law or international trade regulations.
5.2Prohibited Activities
Users may not:
Create multiple accounts to bypass transaction limits or bans.
Provide false information or fraudulent documentation.
Use Escora for money laundering or terrorist financing.
Collude with other parties to manipulate the escrow system.
Harass, threaten, or abuse other users or Escora staff.
Attempt to bypass security measures.
Use Escora to arrange transactions that are then completed outside the platform.
06Reporting and Compliance
6.1Internal and Regulatory Reporting
Suspicious activities are reported internally to our compliance officer for investigation. When required by law, we report suspicious activity to the Nigerian Financial Intelligence Unit and other relevant authorities, and we cooperate fully with law enforcement investigations and regulatory requests.
6.2Record Keeping
We maintain records of all transactions, KYC documentation, suspicious activity investigations, and communication logs used for dispute resolution. These records are securely stored and accessible only to authorized compliance personnel and regulators.
07Consequences and Customer Cooperation
7.1Consequences of Violations
Users who violate this policy or engage in suspicious activity face:
Immediate transaction holds and account suspension.
Permanent ban from the platform.
Reporting to law enforcement and regulatory authorities.
Potential legal action.
7.2Customer Cooperation
Users are required to:
Provide accurate and truthful information.
Respond promptly to verification requests.
Report suspicious activity they observe.
Comply with reasonable requests from our compliance team.
Failure to cooperate may result in account restrictions or termination.
08General
8.1Related Policies
This policy works alongside our Terms of Service, Privacy Policy, and Dispute Resolution Policy, which together govern your full use of Escora.
8.2Policy Updates
This policy may be updated periodically to reflect regulatory changes or improvements to our compliance program. Material changes will be communicated through our website and WhatsApp. Continued use of Escora after an update means you accept the revised policy.
8.3Contact
Questions about this policy, or reports of suspicious activity, can be sent to compliance@getescora.com or hello@getescora.com.
