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AML & KYC Policy

Anti-Money Laundering & Know Your Customer Policy  ·  Last updated: 1 March 2025

Contents
1. Our Commitment 2. KYC Verification 3. Risk-Based Approach 4. Transaction Monitoring 5. PEPs 6. Sanctions Screening 7. Reporting Obligations 8. Record Keeping 9. Contact

Our Commitment: Flux Escrow is fully committed to preventing money laundering, terrorist financing, and financial crime. Compliance is not optional — it is foundational to everything we do.

1. Our Commitment

Flux Escrow Ltd operates in full compliance with the UK Proceeds of Crime Act 2002 (POCA), the UK Money Laundering Regulations 2017 (as amended), and applicable anti-money laundering (AML) regulations in every jurisdiction we serve. We maintain a dedicated compliance function led by a qualified Money Laundering Reporting Officer (MLRO).

2. Know Your Customer (KYC) Verification

All users must complete KYC verification before transacting above defined thresholds. Our KYC process is structured in tiers:

  • Level 1 (Basic): Email and phone verification. Transaction limit: $500 per transaction.
  • Level 2 (Identity): Government-issued photo ID and selfie/liveness verification. Limit: $10,000 per transaction.
  • Level 3 (Advanced): Proof of address and source of funds declaration. For business accounts: company registration, beneficial ownership, and director verification. Limit: $100,000 per transaction.

Documents must be valid, government-issued, and unexpired. All documents are processed by our regulated identity verification partners and stored securely in accordance with our Privacy Policy.

3. Risk-Based Approach

We apply a risk-based approach to customer due diligence. All users are assessed at onboarding and on an ongoing basis. Factors that may elevate a user's risk rating include:

  • Transactions involving high-risk jurisdictions (FATF grey/blacklisted countries)
  • Unusual transaction patterns inconsistent with stated business purpose
  • Politically Exposed Person (PEP) status or association
  • Adverse media coverage or sanctions list matches

High-risk users undergo enhanced due diligence (EDD) and are subject to increased monitoring and manual review of transactions.

4. Transaction Monitoring

All transactions on the platform are subject to automated and human monitoring. Our systems flag activity including but not limited to: structuring (breaking large amounts into multiple smaller transactions to avoid reporting thresholds), rapid cycling of funds, transactions inconsistent with user profile or stated purpose, and sudden changes in transaction patterns.

Flagged transactions are reviewed by our compliance team. We may request additional documentation or explanation before allowing a flagged transaction to proceed.

5. Politically Exposed Persons (PEPs)

Users identified as PEPs — or close associates or family members of PEPs — are automatically elevated to high-risk status and subject to enhanced due diligence regardless of transaction size. PEP status does not automatically disqualify a user from using the platform, but mandatory additional scrutiny applies. Senior management approval is required before onboarding a PEP.

6. Sanctions Screening

All users and transactions are screened against international sanctions lists at onboarding and on a continuous basis. Lists include:

  • OFAC (US Office of Foreign Assets Control)
  • UK HM Treasury Financial Sanctions
  • European Union Consolidated Sanctions List
  • UN Security Council Consolidated List

Any match results in immediate account suspension and fund freezing pending compliance review. Use of the platform by sanctioned individuals or entities is strictly prohibited.

7. Reporting Obligations

Flux Escrow is legally required to submit Suspicious Activity Reports (SARs) to the UK National Crime Agency (NCA) where we have knowledge or suspicion of money laundering or terrorist financing. We are legally prohibited from notifying users when a SAR has been filed (a criminal offence known as "tipping off"). We cooperate fully with all lawful requests from financial intelligence units and law enforcement agencies globally.

8. Record Keeping

All AML and KYC records — including transaction records, customer identification documents, due diligence files, and SAR records — are retained for a minimum of 5 years from the end of the business relationship, as required by UK Money Laundering Regulations. Records may be retained longer where required by a specific legal obligation.

9. Compliance Contact

For AML or KYC-related enquiries:

Compliance Team / MLRO
Flux Escrow Ltd
Email: [email protected]

If you believe your account was incorrectly flagged, you may submit an appeal with supporting documentation to our compliance team. Appeals are reviewed within 10 business days.