Anti-Money Laundering Policy

AccsMarkets is committed to the highest standards of Anti-Money Laundering (AML) compliance. This policy establishes the framework we use to detect, prevent, and report money laundering, terrorist financing, and other financial crimes conducted through our platform.

As a digital escrow platform facilitating cryptocurrency transactions, we recognize our obligation to maintain robust compliance controls proportionate to the risks we face.

We implement tiered identity verification based on transaction volume:

• Email verification — Required for all accounts. Allows browsing and limited activity.
• Phone verification — Required before creating escrow transactions over $100.
• ID verification — Required for cumulative transaction volume over $1,000. Government-issued photo ID and proof of address.

We reserve the right to request additional documentation at any time if our risk assessment indicates elevated risk.

Our automated monitoring systems flag transactions that exhibit suspicious patterns including:

• Unusually large transactions relative to account history
• Rapid successive transactions (structuring behavior)
• Transactions involving jurisdictions subject to sanctions
• Multiple accounts linked to the same identity
• Attempts to circumvent verification requirements

All flagged transactions undergo manual review by our compliance team before processing.

Escrows at or above the platform's high-value threshold — currently $500, configurable by AccsMarkets and shown to admins in the platform settings — are automatically flagged as high-value transactions. A high-value escrow may require additional safeguards before funds are released, such as a transfer-manager handover step or video verification of the handover, depending on the listing's platform and our current risk assessment.

For large or unusual transactions, we reserve the right to ask you to explain the source of the funds being deposited or withdrawn (for example, the origin of a large crypto deposit) before we process it. Failure to provide a satisfactory explanation may result in the transaction being held, declined, or reported as suspicious activity as described below.

When our monitoring identifies potentially suspicious activity, we take the following steps:

1. Immediately suspend the affected transaction(s).
2. Conduct enhanced due diligence on the involved parties.
3. File a Suspicious Activity Report (SAR) with the relevant financial intelligence unit where required by law.
4. Cooperate fully with law enforcement inquiries.

Users may not be informed that a report has been filed, as "tipping off" is prohibited under most AML regulations.

We maintain records of all transactions and identity verification documents for a minimum of 5 years, including:

• Transaction amounts, dates, and parties involved
• Cryptocurrency wallet addresses used
• Identity verification documents and results
• Communications related to flagged transactions
• Internal risk assessments and compliance decisions

Violation of this policy or applicable AML laws may result in:

• Immediate account suspension or permanent ban
• Freezing of funds pending investigation
• Reporting to relevant law enforcement authorities
• Forfeiture of platform privileges

For questions about our AML policy, contact our compliance team at [email protected].