AML / KYC POLICY

Last updated: 13 August 2026

Finance Act Limited, trading as ESCALO («ESCALO», «we», «us», or «our»), is committed to maintaining effective systems and controls designed to prevent its business, services, technology and financial infrastructure from being misused for money laundering, terrorist financing, fraud, sanctions evasion or other forms of financial crime.

This AML / KYC Policy describes the principles and controls that ESCALO applies to customer onboarding, customer due diligence, risk assessment, transaction monitoring, sanctions screening and ongoing compliance.

ESCALO applies a risk-based approach. The nature, extent and intensity of due diligence and monitoring may vary depending on the characteristics and risk profile of a customer, transaction, jurisdiction, product, payment route or business relationship.

This Policy should be read together with ESCALO’s Privacy Policy, Terms & Conditions / Terms of Use, and any applicable customer or service-specific agreements.

1. Company Information

The company responsible for the ESCALO business is:

Finance Act Limited
Trading as: ESCALO
Company number: 16839569

Registered office:

58 Oswald Terrace
Sunderland
England
SR2 9RP

Email:
support@escalo.uk

In this Policy, «ESCALO», «we», «us» and «our» refer to Finance Act Limited trading as ESCALO.

2. Purpose of This Policy

The purpose of this Policy is to establish a framework for identifying, assessing and managing financial crime risks associated with ESCALO’s business activities.

The framework is designed to:

• prevent ESCALO from being misused for money laundering;
• prevent or mitigate terrorist financing risks;
• identify and manage fraud risks;
• identify sanctions-related risks;
• establish appropriate customer identification and verification procedures;
• understand the nature and purpose of business relationships;
• identify beneficial owners and controlling persons;
• assess customer and transaction risk;
• monitor activity for unusual or suspicious behaviour;
• maintain appropriate records;
• escalate potential financial crime concerns;
• comply with applicable legal and regulatory obligations;
• support a culture of financial crime prevention across the organisation.

ESCALO recognises that financial crime risks may change over time and therefore reviews its controls and procedures on an ongoing basis.

3. Risk-Based Approach

ESCALO applies a risk-based approach to AML and financial crime prevention.

This means that resources and controls are proportionate to the level and nature of risk identified.

A risk-based approach allows ESCALO to consider factors including:

• customer type;
• ownership and control structure;
• business activity;
• geography;
• jurisdictional exposure;
• source of funds;
• source of wealth where relevant;
• transaction behaviour;
• payment routes;
• expected transaction volumes;
• products and services used;
• counterparties;
• delivery channels;
• sanctions exposure;
• adverse information;
• fraud indicators;
• unusual or inconsistent activity.

A higher-risk relationship may require additional information, enhanced due diligence, more frequent review or increased transaction monitoring.

A lower-risk relationship may be subject to proportionate standard controls.

Risk classification does not permanently determine a customer’s risk level. A customer’s risk profile may change as new information becomes available or as activity changes.

4. Business-Wide Risk Assessment

ESCALO maintains a business-wide approach to identifying and assessing financial crime risks.

The assessment considers risks arising from:

• customers;
• beneficial owners;
• jurisdictions;
• products and services;
• transaction types;
• payment channels;
• counterparties;
• technology;
• delivery channels;
• third-party relationships;
• operational processes;
• emerging financial crime typologies.

The business-wide risk assessment informs the design and implementation of:

• customer due diligence;
• enhanced due diligence;
• transaction monitoring;
• sanctions screening;
• fraud controls;
• customer acceptance criteria;
• staff training;
• compliance monitoring;
• internal controls.

The assessment is reviewed periodically and when material changes occur in the business, its services, customer base, jurisdictions, technology or risk environment.

This approach reflects the FCA’s expectation that a firm’s business-wide risk assessment should drive its CDD, monitoring and wider financial crime control framework.

5. Customer Due Diligence

Customer Due Diligence («CDD») is a core component of ESCALO’s financial crime control framework.

CDD is designed to allow ESCALO to:

• identify the customer;
• verify the customer’s identity;
• identify beneficial owners;
• understand ownership and control;
• understand the purpose and intended nature of the relationship;
• assess relevant financial crime risks;
• establish whether additional due diligence is required.

The information and documentation required will depend on the type of customer, service, transaction and risk profile.

CDD may be conducted before a business relationship is established and may continue throughout the relationship.

The FCA describes CDD as including identification and verification of customers and beneficial owners and obtaining information on the purpose and intended nature of the business relationship.

6. Individual Customer Identification

Where ESCALO is required to verify an individual, information may include:

• full legal name;
• date of birth;
• nationality;
• residential address;
• country of residence;
• government-issued identification;
• identification document number;
• document issue and expiry information;
• contact details;
• occupation or professional activity;
• other information necessary to assess the relationship.

Verification may be conducted using appropriate independent and reliable sources.

Additional information may be requested where the initial information is insufficient, inconsistent or indicates elevated risk.

7. Corporate Customer Due Diligence

For corporate or other legal entity customers, ESCALO may obtain information including:

• legal name;
• trading name;
• company registration number;
• registered address;
• principal place of business;
• jurisdiction of incorporation;
• nature of business;
• website and publicly available information;
• constitutional or incorporation documents;
• directors and officers;
• ownership structure;
• beneficial ownership;
• authorised representatives;
• expected account or transaction activity;
• purpose and intended nature of the relationship.

ESCALO may use company registers, official records, reliable databases and other appropriate sources to verify corporate information.

8. Beneficial Ownership

ESCALO seeks to identify the natural persons who ultimately own or control a customer where applicable.

Depending on the legal structure, this may include identifying:

• shareholders;
• persons exercising voting control;
• persons exercising ultimate effective control;
• directors or equivalent controlling persons;
• individuals acting on behalf of the customer;
• other persons who meet the applicable beneficial ownership criteria.

Where the ownership structure is complex, ESCALO may request additional documentation or information to understand the structure and identify the relevant individuals.

A customer may be required to provide an ownership chart or equivalent information where necessary.

9. Authorised Representatives

ESCALO may verify individuals acting on behalf of a customer.

This may include confirming:

• identity;
• role;
• authority to act;
• relationship with the customer;
• contact information.

Where appropriate, ESCALO may request evidence of authority, such as:

• corporate resolutions;
• mandates;
• powers of attorney;
• account authorisation documentation;
• other appropriate evidence.

ESCALO may restrict access or activity where authority cannot be adequately established.

10. Purpose and Intended Nature of the Relationship

As part of onboarding, ESCALO may seek to understand:

• why the customer requires the relationship;
• the nature of the customer’s business;
• expected transaction activity;
• expected transaction volumes;
• relevant markets;
• expected jurisdictions;
• expected payment flows;
• counterparties;
• source of funds;
• source of wealth where relevant;
• anticipated use of ESCALO services.

The purpose of this assessment is to establish a reasonable understanding of the expected relationship and identify activity that may be inconsistent with the customer’s stated profile.

11. Source of Funds

Where appropriate, ESCALO may request information or documentation concerning the source of funds.

«Source of funds» refers to the origin of the particular funds involved in a transaction or business relationship.

Depending on the circumstances, evidence may include:

• bank statements;
• transaction records;
• business invoices;
• financial statements;
• sale agreements;
• investment documentation;
• payroll or employment evidence;
• corporate records;
• other reliable supporting documentation.

The information required will depend on the customer’s circumstances and the assessed risk.

12. Source of Wealth

For customers or relationships where the risk profile warrants it, ESCALO may seek information concerning source of wealth.

«Source of wealth» concerns the origin of a customer’s overall wealth or assets rather than the source of a particular transaction.

Evidence may include information relating to:

• business ownership;
• employment;
• investments;
• property;
• inheritance;
• sale of businesses or assets;
• other legitimate sources of wealth.

ESCALO may request documentary evidence where appropriate.

Source of funds and source of wealth are distinct concepts and may require different information.

13. Enhanced Due Diligence

Enhanced Due Diligence («EDD») may be applied where a customer, transaction, jurisdiction, product or other circumstance presents a higher level of financial crime risk.

EDD may include:

• additional identification information;
• additional verification;
• detailed ownership analysis;
• additional information concerning the purpose of the relationship;
• source-of-funds verification;
• source-of-wealth verification;
• additional information about business activities;
• additional information about counterparties;
• increased transaction monitoring;
• more frequent customer reviews;
• senior-level approval;
• additional restrictions or conditions.

EDD is not necessarily limited to a single onboarding event. It may continue throughout the relationship where the elevated risk remains relevant.

14. High-Risk Jurisdictions

ESCALO may apply enhanced controls where a customer, beneficial owner, counterparty, transaction or other relevant connection involves a jurisdiction presenting elevated financial crime risk.

Relevant factors may include:

• jurisdictions identified by applicable authorities as high risk;
• significant deficiencies in AML controls;
• sanctions exposure;
• corruption risk;
• organised crime risk;
• terrorist financing risk;
• fraud risk;
• regulatory concerns;
• other credible risk indicators.

Where applicable, ESCALO will apply enhanced due diligence and ongoing monitoring in accordance with relevant legal and regulatory requirements.

UK requirements specifically provide for enhanced due diligence and enhanced ongoing monitoring in relevant relationships and transactions involving high-risk third countries.

15. Politically Exposed Persons

ESCALO may identify whether a customer, beneficial owner or relevant connected person is a Politically Exposed Person («PEP»), a family member of a PEP or a known close associate where applicable.

PEP status does not automatically mean that ESCALO will refuse a relationship.

However, where enhanced measures are required, ESCALO may apply additional controls, which may include:

• senior management approval;
• additional information regarding source of wealth;
• additional information regarding source of funds;
• enhanced ongoing monitoring;
• periodic reassessment of the relationship.

PEP-related controls are applied in accordance with applicable legal requirements and a risk-based assessment.

16. Sanctions Screening

ESCALO maintains controls designed to identify sanctions risks relevant to its activities.

Screening may be conducted against applicable sanctions information and other relevant data sources.

Depending on the circumstances, screening may include:

• customers;
• beneficial owners;
• directors;
• authorised representatives;
• counterparties;
• payment recipients;
• other relevant parties.

Screening may occur:

• during onboarding;
• periodically during the relationship;
• before or during relevant transactions;
• when information changes;
• when sanctions regimes or risk information changes.

Where a potential match is identified, ESCALO may conduct additional review before determining whether the match is genuine and what action is appropriate.

ESCALO may suspend or reject activity where required by applicable sanctions laws or other legal obligations.

The FCA has emphasised that robust CDD at onboarding and ongoing reviews can help firms identify sanctions risks throughout the customer lifecycle.

17. Adverse Media and Open-Source Information

Where appropriate, ESCALO may review publicly available information to identify potential financial crime, regulatory, reputational or other relevant risks.

Sources may include:

• official registers;
• regulatory publications;
• court information;
• reputable news sources;
• public corporate records;
• other reliable publicly available sources.

Adverse information does not automatically establish wrongdoing.

Potentially relevant information may be assessed in context, including its:

• reliability;
• recency;
• relevance;
• source;
• severity;
• relationship to the customer;
• potential financial crime implications.

18. Fraud Prevention

ESCALO recognises fraud as a significant financial crime risk.

Controls may include:

• identity verification;
• transaction monitoring;
• behavioural analysis;
• device and access monitoring;
• payment verification;
• anomaly detection;
• account controls;
• manual investigation;
• transaction restrictions;
• customer communication;
• third-party fraud prevention tools.

Where fraudulent activity is suspected, ESCALO may restrict or suspend relevant activity while an investigation is conducted.

19. Transaction Monitoring

ESCALO may monitor transactions and other activity to identify patterns that may be inconsistent with a customer’s expected profile or may indicate financial crime risk.

Monitoring may consider:

• transaction volume;
• transaction frequency;
• transaction value;
• counterparties;
• jurisdictions;
• payment routes;
• changes in transaction behaviour;
• unusual transaction patterns;
• rapid movement of funds;
• activity inconsistent with stated business activity;
• other risk indicators.

Monitoring may be automated, manual or a combination of both.

A transaction or activity generating an alert does not necessarily mean that financial crime has occurred.

Alerts may be reviewed and investigated based on the available information and applicable risk procedures.

20. Ongoing Customer Monitoring

CDD does not necessarily end when a customer is onboarded.

ESCALO may periodically review customer information to determine whether it remains accurate and appropriate.

Ongoing monitoring may consider:

• changes in ownership;
• changes in directors;
• changes in business activity;
• changes in geography;
• changes in transaction behaviour;
• sanctions exposure;
• adverse media;
• changes in risk indicators;
• unusual activity;
• changes in expected transaction volumes.

The frequency and depth of review may depend on the customer’s risk classification.

21. Customer Risk Classification

ESCALO may assign risk classifications to customers or relationships.

Risk factors may include:

• customer type;
• ownership structure;
• geography;
• business activity;
• products and services;
• transaction profile;
• source of funds;
• source of wealth;
• sanctions exposure;
• PEP status;
• adverse media;
• fraud indicators;
• complexity;
• transparency of ownership;
• other relevant financial crime factors.

Risk classifications may be reviewed when material information changes.

The existence of a risk classification does not by itself imply that a customer has engaged in unlawful activity.

22. Unusual or Suspicious Activity

ESCALO maintains procedures for identifying and escalating potentially suspicious activity.

Indicators may include:

• activity inconsistent with the customer’s stated business;
• unexplained changes in transaction behaviour;
• unusual transaction patterns;
• unexplained third-party activity;
• complex structures without a clear legitimate purpose;
• unexplained movement of funds;
• inconsistent information;
• attempts to circumvent controls;
• potential sanctions exposure;
• fraud indicators;
• information suggesting possible money laundering or terrorist financing.

The presence of an indicator does not automatically mean that suspicious activity has occurred.

Potential concerns are assessed using a risk-based approach.

23. Internal Escalation

Employees and relevant personnel are expected to escalate financial crime concerns through the appropriate internal channels.

Escalation may occur where there is:

• suspected money laundering;
• suspected terrorist financing;
• suspected fraud;
• sanctions concern;
• unexplained high-risk activity;
• significant inconsistency in customer information;
• suspected misuse of ESCALO services;
• another material financial crime concern.

Relevant personnel should not attempt to conduct investigations beyond their authority or inform customers of confidential internal processes.

24. Suspicious Activity Reports

Where ESCALO is subject to a legal obligation to report suspected money laundering or terrorist financing to the relevant authority, it will follow the applicable reporting requirements.

Where appropriate, reports may be made to the relevant UK authorities, including the National Crime Agency («NCA»).

ESCALO will maintain appropriate procedures for:

• identifying reportable concerns;
• internal escalation;
• review;
• decision-making;
• reporting;
• record keeping.

Where applicable, ESCALO will comply with restrictions concerning disclosure of suspicious activity reports and related information.

ESCALO will not inform a customer that a report has been made where doing so would be unlawful.

25. Tipping Off

ESCALO personnel must not improperly disclose information that could constitute unlawful «tipping off» or otherwise compromise a financial crime investigation.

This may include disclosing:

• that a suspicious activity report has been made;
• that a report is being considered;
• confidential law enforcement information;
• details of an internal investigation where disclosure is prohibited.

Information will be shared internally only on a need-to-know basis and in accordance with applicable law and internal procedures.

26. Record Keeping

ESCALO maintains records necessary to demonstrate appropriate compliance with applicable AML and financial crime requirements.

Records may include:

• customer identification information;
• verification evidence;
• beneficial ownership information;
• customer risk assessments;
• source-of-funds information;
• source-of-wealth information;
• transaction records;
• monitoring alerts;
• investigation records;
• sanctions screening results;
• relevant communications;
• decisions and approvals;
• compliance reviews;
• training records.

Records will be retained for the applicable legal or regulatory period.

Where no specific period is prescribed, ESCALO will apply a proportionate retention period based on legal, regulatory, operational and risk considerations.

27. Data Protection

AML and KYC processes require the collection and processing of personal and, in some circumstances, sensitive information.

ESCALO processes personal data in accordance with applicable data protection law.

Personal data collected for AML/KYC purposes may be used for:

• identity verification;
• customer due diligence;
• sanctions screening;
• fraud prevention;
• transaction monitoring;
• regulatory compliance;
• financial crime prevention;
• legal obligations;
• risk management.

Further information about how ESCALO processes personal data is available in our Privacy Policy.

Data protection rights may be subject to legal restrictions where information must be retained or processed for regulatory, legal or financial crime prevention purposes.

28. Third-Party Compliance Providers

ESCALO may use specialist third-party providers to support compliance activities.

These may provide services including:

• identity verification;
• document verification;
• sanctions screening;
• PEP screening;
• adverse media screening;
• fraud detection;
• transaction monitoring;
• corporate verification;
• risk intelligence;
• secure data processing.

ESCALO remains responsible for appropriately managing its compliance framework even where certain activities are supported by third-party technology or service providers.

Third-party providers may be subject to contractual, security, confidentiality and data protection requirements.

29. Reliance on Information

ESCALO may rely on information obtained from:

• customers;
• authorised representatives;
• corporate registers;
• government sources;
• regulators;
• financial institutions;
• specialist verification providers;
• reputable commercial databases;
• publicly available sources;
• other reliable sources.

Where information is inconsistent, incomplete or unreliable, ESCALO may request clarification or additional evidence.

30. Customer Cooperation

Customers are expected to cooperate with reasonable AML/KYC requests.

This includes providing:

• accurate information;
• complete documentation;
• ownership information;
• identification documents;
• information regarding business activity;
• information regarding transactions;
• source-of-funds information where requested;
• source-of-wealth information where requested;
• updated information when circumstances change.

Failure to provide requested information may result in:

• delayed onboarding;
• additional review;
• restricted activity;
• rejected transactions;
• suspension;
• termination of the relationship.

Any such action will be taken in accordance with applicable law and contractual arrangements.

31. Refusal, Restriction or Termination

ESCALO may refuse to onboard a customer or may restrict, suspend or terminate a relationship where:

• required KYC information cannot be obtained;
• information cannot be adequately verified;
• the customer presents unacceptable financial crime risk;
• beneficial ownership cannot be established;
• sanctions concerns cannot be resolved;
• the customer provides materially false information;
• activity appears inconsistent with the stated business purpose;
• there are reasonable grounds to suspect financial crime;
• continued activity may expose ESCALO to legal or regulatory risk;
• applicable law requires action;
• a competent authority requires or directs action.

Where legally permitted, ESCALO may provide an explanation.

However, ESCALO may be unable to provide detailed reasons where disclosure could compromise an investigation, breach a legal obligation or create another legal or security risk.

32. Prohibited or Restricted Activity

ESCALO does not knowingly permit its services or infrastructure to be used for unlawful activities.

This includes activities involving:

• money laundering;
• terrorist financing;
• sanctions evasion;
• fraud;
• proceeds of crime;
• identity theft;
• corruption;
• bribery;
• unlawful financial activity;
• deliberate circumvention of compliance controls.

ESCALO may apply additional restrictions to activities or customer categories that present elevated financial crime, legal, regulatory or reputational risk.

33. Sanctions Compliance

ESCALO seeks to comply with applicable sanctions requirements relevant to its business activities.

Where appropriate, ESCALO may screen customers, beneficial owners, counterparties and transactions against applicable sanctions information.

Potential sanctions matches will be reviewed before a final determination is made.

ESCALO may block, reject, delay or suspend relevant activity where required or permitted by applicable law.

34. Terrorist Financing

ESCALO maintains controls designed to identify and mitigate terrorist financing risks.

Relevant indicators may include:

• unusual transaction patterns;
• unexplained movement of funds;
• high-risk jurisdictions;
• sanctions exposure;
• suspicious counterparties;
• unusual payment routes;
• other relevant intelligence.

Where concerns arise, ESCALO may conduct enhanced review and take appropriate action in accordance with applicable law.

35. Bribery and Corruption

ESCALO does not tolerate bribery or corruption in connection with its business.

Employees, customers, partners and other relevant persons must not use ESCALO’s services to facilitate:

• bribery;
• corruption;
• improper payments;
• unlawful inducements;
• concealment of corrupt proceeds.

Potential bribery or corruption concerns may be escalated for investigation.

36. Training and Awareness

ESCALO seeks to ensure that relevant employees and personnel understand their responsibilities concerning financial crime prevention.

Training may cover:

• AML principles;
• KYC and CDD;
• enhanced due diligence;
• sanctions;
• fraud;
• suspicious activity;
• escalation procedures;
• data protection;
• record keeping;
• relevant financial crime risks.

Training may be provided during onboarding and periodically thereafter, depending on the employee’s role and responsibilities.

Additional training may be provided when material changes occur in the regulatory or risk environment.

37. Governance and Accountability

ESCALO’s senior management is responsible for ensuring that appropriate financial crime controls are established and maintained.

Responsibilities may include:

• understanding the financial crime risks facing the business;
• approving appropriate policies and procedures;
• ensuring adequate resources;
• reviewing significant financial crime risks;
• overseeing compliance performance;
• supporting appropriate escalation;
• ensuring relevant personnel receive appropriate training;
• reviewing material weaknesses;
• supporting remediation and continuous improvement.

The FCA’s Financial Crime Guide emphasises that senior management should take responsibility for a firm’s AML measures and understand the money laundering risks to which the firm is exposed.

38. Compliance Monitoring and Testing

ESCALO may conduct periodic reviews of its AML/KYC framework to assess whether controls remain effective.

Monitoring may consider:

• customer onboarding;
• CDD quality;
• EDD implementation;
• sanctions screening;
• transaction monitoring;
• risk classification;
• record keeping;
• escalation procedures;
• staff training;
• third-party compliance controls.

Where weaknesses are identified, ESCALO may implement corrective actions, including:

• process improvements;
• additional controls;
• enhanced monitoring;
• staff training;
• system changes;
• remediation of customer files;
• independent review where appropriate.

The FCA’s 2026 review of firms’ CDD processes highlights policies and procedures, CDD/EDD processes, and compliance monitoring and audit as key areas of effective control.

39. Independent Review

Where appropriate and proportionate to the nature and scale of the business, ESCALO may arrange independent reviews of aspects of its financial crime framework.

The scope may include:

• governance;
• customer due diligence;
• risk assessment;
• sanctions;
• transaction monitoring;
• financial crime controls;
• compliance monitoring.

The frequency and scope of independent testing may be determined using a risk-based approach.

40. Outsourcing

Where ESCALO outsources elements of its compliance or operational processes, it will seek to maintain appropriate oversight.

Outsourcing may involve:

• identity verification providers;
• screening providers;
• transaction monitoring technology;
• cloud infrastructure;
• compliance databases;
• specialist professional advisers.

Outsourcing a process does not remove the need for appropriate governance, oversight, contractual controls and monitoring.

41. Emerging Financial Crime Risks

ESCALO recognises that financial crime methods evolve.

Emerging risks may include:

• synthetic identities;
• identity fraud;
• account takeover;
• sophisticated payment fraud;
• digital manipulation;
• cyber-enabled financial crime;
• misuse of digital financial infrastructure;
• complex ownership structures;
• new typologies involving digital assets;
• emerging sanctions evasion techniques;
• misuse of third-party accounts;
• rapidly changing payment routes.

ESCALO may update its controls as new risks, typologies, regulatory requirements and intelligence emerge.

42. Policy Review

This Policy will be reviewed periodically and may be updated where appropriate.

A review may be triggered by:

• changes in applicable law;
• regulatory developments;
• changes to ESCALO’s business model;
• new products or services;
• changes in customer profiles;
• changes in geographic exposure;
• new financial crime typologies;
• material incidents;
• audit or compliance findings;
• changes in technology.

The Policy will be updated where necessary to remain appropriate to the company’s risk profile.

43. No Guarantee of Zero Financial Crime Risk

ESCALO maintains systems and controls designed to prevent, detect and mitigate financial crime.

However, no financial institution, technology platform or business can guarantee that financial crime will never occur.

Controls are designed to reduce risk to an appropriate level and to identify and respond to potential issues as effectively as reasonably possible.

ESCALO continually reviews and improves its financial crime framework based on experience, regulatory developments and emerging risks.

44. Confidentiality of AML/KYC Processes

Information obtained through AML/KYC procedures may be confidential.

ESCALO may be restricted from disclosing:

• internal risk assessments;
• screening results;
• monitoring rules;
• investigation information;
• suspicious activity reports;
• law enforcement requests;
• internal escalation records;
• reasons for certain compliance decisions.

These restrictions may arise from legal obligations, regulatory requirements, confidentiality considerations or the need to protect the integrity of financial crime investigations.

45. Contact

Questions regarding this Policy or general AML/KYC matters may be directed to:

Finance Act Limited trading as ESCALO

Company number: 16839569

Registered office:
58 Oswald Terrace
Sunderland
England
SR2 9RP

Email:
support@escalo.uk

Please do not send confidential identity documents or sensitive financial information by ordinary email unless specifically requested through an approved ESCALO process.

46. Relationship With Other Policies

This AML / KYC Policy should be read together with the following ESCALO documentation:

• Privacy Policy;
• Terms & Conditions / Terms of Use;
• Cookie Policy;
• customer agreements;
• applicable service-specific terms;
• sanctions and compliance procedures;
• internal risk management procedures.

Where a separate contractual or regulatory document contains more specific requirements, that document may apply to the relevant relationship or service.

47. Important Regulatory Disclaimer

This Policy describes ESCALO’s approach to AML, KYC and financial crime risk management.

Nothing in this Policy should be interpreted as a representation that Finance Act Limited is authorised or regulated by the Financial Conduct Authority or another regulator for a particular regulated activity unless such authorisation or registration is expressly confirmed in the applicable regulatory documentation.

Where a particular ESCALO service is subject to specific regulatory requirements, those requirements and the applicable service documentation will govern the relevant activity.

48. Final Statement

ESCALO is committed to maintaining a strong culture of financial crime prevention.

Our approach is based on:

Know the customer.
Understand the relationship.
Assess the risk.
Monitor the activity.
Escalate concerns.
Protect the integrity of the financial system.

ESCALO will continue to develop its AML/KYC framework as its business, technology, customer base and regulatory environment evolve.

Finance Act Limited trading as ESCALO
Company number: 16839569
58 Oswald Terrace, Sunderland, England, SR2 9RP

support@escalo.uk

Last updated: 13 August 2026