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.
1. Purpose and Scope
This policy applies to all users of Escora's escrow payment platform. We are committed to complying with all applicable Nigerian anti-money laundering laws and regulations, including the Money Laundering (Prohibition) Act and guidelines from the Central Bank of Nigeria (CBN) and the Nigerian Financial Intelligence Unit (NFIU).
Money laundering is the process of making illegally obtained money appear legitimate. Terrorist financing involves providing financial support to terrorist organizations or activities. Escora has zero tolerance for these activities and actively works to prevent our platform from being used for such purposes.
2. Know Your Customer (KYC)
2.1 Customer Identification
We verify the identity of all users through a tiered verification system:
Tier 1
Requirements: WhatsApp phone number, legal name, and bank account details
Verification: Automatically through our payment processor
Transaction limit: Up to ₦100,000
Tier 2
Requirements: National Identification Number (NIN) and passport photograph
Verification: NIN information verified against official government databases
Transaction limit: Up to ₦500,000
Tier 3
Requirements: Bank Verification Number (BVN) and passport photograph
Verification: BVN information verified through authorized verification services
Transaction limit: Up to ₦1,000,000
2.2 Ongoing Monitoring
We continuously monitor user accounts and transactions for:
Users may be required to update their KYC information periodically or when suspicious activity is detected.
Changes in behavior patterns
Significant increases in transaction volume or frequency
Unusual or suspicious activities that may indicate money laundering
3. Transaction Limits and Controls
3.1 Transaction Limits
To prevent large-scale money laundering, we enforce the following limits:
These limits help us identify and prevent unusual financial activity while allowing legitimate users to conduct normal business.
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
3.2 Enhanced Due Diligence
Transactions approaching these limits are subject to enhanced review. Users who consistently transact at high volumes may be required to provide additional documentation including:
Business registration certificates
Proof of income or business activity
Detailed explanations of transaction purposes
4. Suspicious Activity Monitoring
4.1 Red Flags
We actively monitor for suspicious patterns that may indicate money laundering:
Unusual transaction frequency:
More than 10 transactions in a single day
Rapid succession of transactions within short time periods
Circular trading patterns:
Repeated transactions between the same buyer and seller
Transactions that appear designed to move money without genuine commerce
Multiple accounts transacting with each other
Suspicious transaction characteristics:
Unusually large or round transaction amounts
Vague or inconsistent item descriptions
Transactions inconsistent with the user's profile or history
Sudden changes in transaction patterns
Evasive behavior:
Reluctance to provide KYC information
Providing false or fraudulent documentation
Attempting to structure transactions to avoid limits or detection
4.2 Automated Detection
Our system automatically flags transactions and users that meet suspicious criteria.
Flagged transactions may be temporarily held for manual review.
Our compliance team investigates all flagged activities within 24-48 hours.
5. Prohibited Activities
Users may not use Escora for:
Transactions involving illegal goods or services including drugs, weapons, stolen property, or counterfeit items
Structuring transactions to evade reporting thresholds or transaction limits
Providing false information or fraudulent documentation
Creating multiple accounts to circumvent KYC requirements or transaction limits
Facilitating transactions that occur outside the Escora platform
Any activity that violates Nigerian laws or international sanctions
6. Reporting and Compliance
6.1 Internal Reporting
Suspicious activities are reported internally to our compliance officer for investigation.
All staff are trained to identify and report potential money laundering indicators.
We maintain detailed records of all investigations and actions taken.
6.2 Regulatory Reporting
When required by law:
We report suspicious activities to the Nigerian Financial Intelligence Unit (NFIU) and other relevant authorities.
We cooperate fully with law enforcement investigations.
We comply with all regulatory requests for information.
6.3 Record Keeping
We maintain comprehensive records of:
These records are securely stored and accessible only to authorized compliance personnel and regulators.
All transactions
KYC documentation
Suspicious activity reports and investigations
Communication logs for dispute resolution purposes
7. Customer Due Diligence
7.1 Risk Assessment
We assess the money laundering risk of each user based on:
Higher-risk users are subject to enhanced monitoring and verification requirements.
Transaction patterns and history
Verification tier and KYC completeness
Geographic location and operating environment
Business type and industry
7.2 Ongoing Due Diligence
We continuously review user activities to ensure they remain consistent with our understanding of their legitimate business or personal needs. Significant changes in transaction patterns trigger additional review and may require updated KYC information.
8. Training and Awareness
Our compliance program is reviewed and updated regularly to reflect changes in regulations and emerging risks.
All Escora staff receive regular training on:
AML regulations and requirements
How to identify suspicious activities
Reporting procedures and responsibilities
The importance of compliance
9. Consequences of Violations
We take all violations seriously and prioritize the safety and integrity of our platform.
Users who violate this AML Policy or engage in suspicious activities face:
Immediate transaction holds and account suspension
Permanent ban from the platform
Reporting to law enforcement and regulatory authorities
Potential legal action
10. Customer Cooperation
Failure to cooperate may result in account restrictions or termination.
Users are required to:
Provide accurate and truthful information
Respond promptly to verification requests
Report suspicious activity they observe
Comply with all reasonable requests from our compliance team
11. Policy Updates
This AML Policy may be updated periodically to reflect regulatory changes, emerging risks, or improvements to our compliance program. Material changes will be communicated to users through our website and WhatsApp. Continued use of Escora after updates constitutes acceptance of the revised policy.
12. Contact Information
For questions about this AML Policy or to report suspicious activity, contact us at:
Email: compliance@getescora.com
Website: www.getescora.com
Our Commitment
Escora is committed to maintaining the highest standards of financial integrity and protecting our platform from misuse. Thank you for your cooperation in keeping our community safe.
Escora — Financial integrity, protected.
