Risk Mitigation

ESCROWEASEPAY RISK MITIGATION POLICY

Effective Date: 30 November 2025
Last Updated: 30 November 2025

---

Escroweasepay is committed to providing a secure, transparent, and reliable escrow service for buyers and sellers. This Risk Mitigation Policy outlines the measures implemented to identify, prevent, manage, and minimize risks associated with escrow transactions.

1. Purpose of This Policy

This policy establishes Escroweasepay’s approach to mitigating financial, operational, legal, fraud, and data security risks while complying with Nigerian laws, AML/CFT regulations, and data protection standards.

2. Scope

• All Escroweasepay users (buyers, sellers, agents, affiliates)
• All transactions conducted on the platform
• All Escroweasepay employees, escrow agents, and service providers
• All systems, processes, and stored data

3. Risk Categories Identified

3.1 Transaction Risk

• Non-delivery or partial delivery of goods or services
• Misrepresentation or substandard delivery
• Buyer or seller default
• Unclear or disputed transaction terms

3.2 Fraud and Financial Crime Risk

• Identity fraud or impersonation
• Payment fraud or chargebacks
• Money laundering or terrorism financing
• Platform circumvention

3.3 Operational Risk

• System outages or service disruptions
• Human or process errors
• Unauthorized access to escrow funds
• Third-party service failures

3.4 Legal and Regulatory Risk

• Non-compliance with Nigerian laws
• Contractual disputes
• Data protection violations

3.5 Cybersecurity and Data Risk

• Data breaches or leaks
• Account compromise
• Hacking or phishing attempts

4. Risk Mitigation Measures

4.1 User Verification and KYC

• Mandatory account registration
• Identity verification when required
• Enhanced due diligence for high-value transactions
• Account suspension for false or suspicious information

4.2 Transaction Controls

• Funds held securely until conditions are met
• Buyer confirmation required before release
• Immutable transaction records and audit logs
• Restrictions on post-initiation changes

Funds remain in escrow until buyer confirmation or a binding Escrow Agent decision.

4.3 Dispute Resolution

• Neutral Escrow Agents assigned
• Mandatory evidence submission
• Structured investigation timelines
• Final and binding decisions

4.4 Fraud Detection and Prevention

• Transaction monitoring and behavior analysis
• IP and device tracking
• Automated and manual fraud reviews
• Immediate action on suspicious activity

4.5 Financial Safeguards

• Segregation of escrow and operational funds
• Controlled fund release procedures
• Use of regulated banks and payment processors
• No investment or lending of escrow funds

4.6 Data Protection and Cybersecurity

• SSL encryption for all transmissions
• Encrypted data storage
• Role-based access control
• Regular security audits

Users are responsible for safeguarding their login credentials.

4.7 Third-Party Risk Management

• Due diligence on service providers
• Confidentiality and compliance obligations
• NDPR-aligned data handling requirements

5. Incident and Breach Management

• Immediate containment and investigation
• User and regulator notification when required
• Corrective actions to prevent recurrence

6. User Responsibilities

• Provide accurate transaction details
• Define clear terms before escrow initiation
• Communicate only through the platform
• Report suspicious activities promptly

7. Limitations of Risk Mitigation

While Escroweasepay implements strong safeguards, no system can eliminate all risk. Escroweasepay does not guarantee transaction success and is not responsible for losses arising from user negligence or platform circumvention.

8. Policy Review and Updates

This policy is reviewed periodically to reflect regulatory, operational, and security developments. Updates take effect upon publication.

9. Contact Information

Escroweasepay Compliance & Risk Department
Email: julia@escroweasepay.com
Phone: +234 80 2132 2952

---

By using Escroweasepay, you acknowledge that you understand the risks associated with escrow transactions and agree to the risk mitigation measures outlined in this policy.