Anti-Money Laundering (AML) Policy

This is a starter text. The site owner must review and adapt it with a qualified adviser for the countries where Middlesman operates before relying on it.

1. Purpose

Middlesman does not allow its escrow service to be used for money laundering, terrorist financing, fraud, sanctions evasion or any other financial crime. This policy explains what we do to prevent it and what we expect from members.

2. Identity checks (KYC)

We may ask members to verify their identity with a government-issued document and a live selfie before they create, fund or receive deals, or when amounts or activity call for it. We may refuse, pause or close an account when identity cannot be verified or the information given is false.

3. Monitoring

We review deals, deposits, withdrawals and wallet activity for unusual patterns, such as amounts or frequencies that do not fit the stated purpose, deals between linked accounts, or funds from high-risk sources. We may ask for information about the source of funds or the purpose of a deal.

4. Prohibited use

Members must not use Middlesman to move proceeds of crime, to finance terrorism, to trade with sanctioned persons or countries, or to hide the origin or owner of funds. Deals for illegal goods or services are forbidden.

5. Reporting and cooperation

Where the law requires it, we report suspicious activity to the competent authorities and may freeze or hold funds while we do. We may be prohibited from telling the member about such a report.

6. Record keeping

We keep records of identity checks, deals and payments for as long as the law requires, even after an account is closed or deleted.

7. Contact

Questions about this policy can be sent through the support page.