Anti-Money Laundering (AML) Policy

Effective 20 July 2026

EscrowPK's commitment to preventing money laundering, terrorist financing, and other financial crime on the platform.

1. Commitment

EscrowPK (Private) Limited is committed to preventing the platform from being used, directly or indirectly, for money laundering, terrorist financing, or any other form of financial crime. This policy is designed to align with applicable Pakistani law and the standards expected of custodial escrow service providers.

2. Prohibited Use

Consistent with Section 14 (Prohibited Transactions) of the Terms & Conditions, EscrowPK may not be used to transact in illegal goods or services, to launder proceeds of crime, to facilitate fraud, to process transactions for sanctioned individuals or entities, to fund gambling, or to structure transactions in a way designed to evade regulatory reporting thresholds.

3. Customer Due Diligence

All users must complete identity verification (KYC) before depositing or receiving funds through escrow, as described in our KYC Policy. EscrowPK reserves the right to request additional information or documentation for higher-value or unusual transactions.

4. Transaction Monitoring

EscrowPK monitors deal activity for patterns consistent with money laundering or structuring, including unusually rapid movement of funds, repeated deals just below verification or fee thresholds, and deals that do not correspond to genuine goods or services.

Accounts or transactions flagged during monitoring may be paused pending review, and additional documentation may be requested from the user before funds are released or refunded.

5. Segregation of Funds

Buyer funds held in escrow are kept in a segregated escrow account, separate from EscrowPK's own operating funds, and are not used for EscrowPK's operating expenses, lending, or investment, consistent with Sections 2 and 3 of the Terms & Conditions.

6. Reporting

Where EscrowPK identifies activity it reasonably suspects to be linked to money laundering, terrorist financing, or other financial crime, it may report that activity to the relevant Pakistani authorities as required or permitted by law, and may restrict or terminate the accounts involved.

7. Recordkeeping

Records of customer identity, transactions, and any suspicious activity reviews are retained for the period required by applicable law, generally not less than five years, to support regulatory inquiries and audits.

8. Staff Awareness

EscrowPK trains relevant staff to recognize red flags for money laundering and financial crime and to escalate concerns internally for review before any related transaction is completed.