Financial crime policy

You do not create an account with Escalator. You pay from your own bank account using your bank's own app, and we send the equivalent USDC on Base to the address you entered. Because the money arrives from a regulated bank, the payer is already identified before we do anything.

That is the core of our approach: use the identity the banking system has already established, rather than asking you to upload documents you have already given your bank.

• Your bank has already completed full customer due diligence on you before opening your account.
• We receive the payer name, the account details and the payment reference with every incoming payment. Anonymous funding is not possible.
• Cash, prepaid cards, third-party crypto deposits and mixers are never accepted.
• Funds only ever travel in one direction: from a named bank account, to a single crypto address chosen at the moment of payment. We do not hold balances for you and we never pay money back out to a different bank account.

• Payer identity. The verified name and account details supplied by the sending bank through our open banking partner.
• Sanctions and watchlists. Payer names are screened against applicable sanctions, terrorist-financing and politically exposed person lists.
• Destination address screening. Every Base address is screened with blockchain analytics before we send. Addresses linked to sanctioned entities, terrorist financing, ransomware, darknet markets, theft or mixers are blocked.
• Behaviour monitoring. Automated rules look for structuring, repeated payments split under thresholds, many payers funding one address, one payer funding many addresses, and other unusual patterns.
• Transaction limits. A maximum of $500 per payment, 3 payments per calendar month, and $500 per calendar month in total. The limits apply to the bank account the money comes from, so a $300 payment leaves $200 for that month. Because every payment is made by bank, our open banking partner identifies the account behind it and the limits cannot be sidestepped by using a different address, device or browser.

Most people will never be asked for anything beyond their bank approval. Where a payment hits a risk trigger, is above our enhanced due diligence threshold, or where a pattern suggests the account holder may not be the real customer, we may ask for proof of identity, proof of source of funds, or an explanation of the purpose of the payment before the crypto is released.

If we cannot complete those checks, we will not send the crypto. We will return the funds to the originating bank account unless we are legally prevented from doing so.

Escalator must not be used to launder money, finance terrorism, evade sanctions, fund weapons proliferation, or move the proceeds of fraud, scams or any other crime. We will block, freeze or reverse payments and file reports with the relevant authorities where we are required to.

Where the law requires it, we will not tell you that a report has been made. That is not us being unhelpful; it is a legal obligation.

Merchants do not open an account with us and receive nothing from us. A merchant simply shares a link; the customer pays their own bank and the crypto goes to the address in that link. Merchants remain responsible for their own regulatory obligations, including their own customer due diligence and tax reporting.

Addresses associated with sanctioned or criminal activity are blocked for everyone, so a merchant using a flagged address will not be able to receive payments through Escalator.

We keep payment records, payer details, screening outcomes and on-chain transaction hashes for the period required by law, typically five years from the date of the payment. Those records are shared only with our regulated payment and screening partners, and with law enforcement or regulators where we are legally obliged to do so. See our privacy policy for how we handle personal data.

If you believe Escalator has been used for financial crime, or you have been tricked into making a payment, contact us immediately at compliance@escalator.to. Crypto transactions cannot be reversed once sent, so speed matters.