VeriEscrowTrustless Protocol
Regulatory Framework

Regulatory Compliance

Our commitment to global regulatory standards and best practices

VARA Aligned
FATF Compliant
GDPR Ready
MiCA Compatible

Non-Custodial Advantage

As a non-custodial platform, VeriEscrow never takes possession, custody, or control of user funds. All assets are held exclusively by audited smart contracts on public blockchains. This architecture fundamentally reduces regulatory risk and provides users with direct control over their digital assets at all times.

1. Compliance Overview

VeriEscrow, operated by Elysium Media FZCO, is committed to maintaining the highest standards of regulatory compliance. As a non-custodial escrow platform, we operate at the intersection of blockchain technology and financial services, requiring us to navigate a complex regulatory landscape across multiple jurisdictions.

We proactively implement compliance measures that often exceed minimum regulatory requirements, ensuring our users can transact with confidence in a secure and legally compliant environment.

2. UAE Regulatory Framework

As a company registered in Dubai, UAE, we operate under one of the world's most progressive virtual asset regulatory frameworks.

VARA (Virtual Assets Regulatory Authority)

Dubai's Virtual Assets Regulatory Authority (VARA) is the world's first independent regulator dedicated to virtual assets. Our operations align with VARA's comprehensive rulebook framework.

Our VARA Alignment
  • Compliance with AML/CFT requirements and sanctions screening
  • Implementation of client risk assessment procedures
  • Technology governance and risk assessment framework (TGRAF)
  • Client asset protection through non-custodial architecture
  • Regular compliance monitoring and reporting protocols

SCA (Securities and Commodities Authority)

We monitor developments from the UAE Securities and Commodities Authority regarding virtual asset regulation at the federal level, ensuring readiness for any additional requirements.

Cabinet Resolution No. 111 of 2022

Our operations comply with Cabinet Resolution No. 111 of 2022 Regulating Virtual Assets and Related Service Providers, the foundational legislation for virtual asset activities in the UAE.

3. FATF Travel Rule Compliance

The Financial Action Task Force (FATF) Travel Rule is a global standard requiring Virtual Asset Service Providers (VASPs) to share originator and beneficiary information for qualifying transactions.

Our Implementation

  • Collection and verification of originator and beneficiary information
  • Secure transmission of required data for transactions above threshold amounts
  • Record-keeping systems that maintain transaction data for regulatory periods
  • Integration with Travel Rule compliance solutions for cross-VASP transfers

Transaction Thresholds

FATF recommended threshold: $1,000 USD equivalent

UAE/VARA threshold: Aligned with FATF recommendations

For transactions above these thresholds, additional identity verification may be required.

As of 2025, the Travel Rule is enforced in 99+ countries globally, and we ensure compliance across all jurisdictions where we operate.

4. AML/KYC Program

Our Anti-Money Laundering (AML) and Know Your Customer (KYC) program is designed to prevent the use of our platform for illicit activities while maintaining a seamless user experience.

Risk-Based Approach

We implement a risk-based approach to customer due diligence, applying enhanced measures proportionate to the assessed risk level of each user and transaction.

Standard Due Diligence

Basic identity verification for standard transactions

Enhanced Due Diligence

Additional verification for high-value transactions, high-risk jurisdictions, or PEPs (Politically Exposed Persons)

Ongoing Monitoring

Continuous transaction monitoring and periodic review of customer risk profiles

Sanctions Screening

All users and transactions are screened against global sanctions lists, including OFAC, UN, EU, and other relevant sanctions regimes. We maintain real-time screening capabilities and immediately block any matches.

Suspicious Activity Reporting

We maintain robust procedures for identifying and reporting suspicious activities to relevant authorities, including filing Suspicious Activity Reports (SARs) within required timeframes.

5. European Regulation (MiCA)

The Markets in Crypto-Assets Regulation (MiCA) establishes a comprehensive regulatory framework for crypto-assets across the European Union.

MiCA Compliance Status

MiCA became fully applicable in December 2024, with transitional provisions extending to July 2026. We actively monitor and align with MiCA requirements for any services offered to EU users.

Non-Custodial Platform Status

Under MiCA Recital 22, services provided 'in a fully decentralised manner without any intermediary' may fall outside the regulation's scope. Our non-custodial architecture, where users maintain full control of their assets through smart contracts, aligns with this principle.

We nevertheless implement MiCA-aligned compliance measures to ensure the highest standards of user protection regardless of regulatory classification.

Transfer of Funds Regulation (TFR)

The EU's Transfer of Funds Regulation, effective December 2024, requires originator and beneficiary information for all crypto transfers regardless of amount. We implement compliant information sharing for EU-related transactions.

DAC8 Tax Reporting

Effective January 2026, DAC8 requires reporting of crypto-asset transactions for tax purposes. We are implementing necessary systems to support DAC8 compliance.

6. Data Protection (GDPR)

We are committed to protecting user data in accordance with the General Data Protection Regulation (GDPR) and other applicable data protection laws.

Data Protection Principles

  • Lawfulness, fairness, and transparency in data processing
  • Purpose limitation—data collected only for specified purposes
  • Data minimization—only collecting necessary information
  • Accuracy—maintaining up-to-date and accurate data
  • Storage limitation—retaining data only as long as necessary
  • Integrity and confidentiality—implementing appropriate security measures

Your Data Rights

Under GDPR and similar regulations, you have rights including access, rectification, erasure, restriction, portability, and objection. See our Privacy Policy for details on exercising these rights.

Blockchain Data Considerations

Blockchain transactions are recorded on public, immutable ledgers. Once data is written to a blockchain, it cannot be modified or deleted. Users should be aware that wallet addresses and transaction data visible on-chain are permanent.

7. Smart Contract Compliance

Our smart contracts are designed with compliance considerations embedded in their architecture.

Security and Auditing

  • All smart contracts undergo rigorous internal security review
  • Implementation of industry-standard security patterns (ReentrancyGuard, CEI pattern)
  • Use of SafeERC20 for secure token transfers
  • Emergency pause functionality for incident response
  • External security audits by reputable firms (planned/completed)

Transparency Features

  • All contract code is verified and publicly readable on block explorers
  • Immutable contracts—no hidden admin functions that could affect user funds
  • Deterministic deployment addresses across supported chains
  • Clear, auditable fee structures with no hidden charges

Built-in Compliance Limits

  • •Maximum parties per escrow: 10 (payers and receivers)
  • •Maximum conditions per escrow: 5
  • •Minimum escrow duration: 1 hour
  • •Maximum escrow duration: 365 days
  • •Minimum escrow amount: 0.001 ETH equivalent

8. Dispute Resolution Compliance

Our dispute resolution system is designed to provide fair, transparent, and compliant outcomes for all parties.

Resolution Mechanism

Disputes are resolved by qualified arbiters within defined timeframes, ensuring timely and fair resolution while maintaining audit trails for regulatory purposes.

Resolution Timeline

Evidence submission period: 72 hours

Arbiter voting period: 48 hours

Maximum total resolution time: 5 days

Arbiter Categories

VeriEscrow Arbiters: Platform-trained resolution specialists

Professional Notaries: External qualified professionals

AI Arbitration: Automated decision system for standard disputes

Custom Arbiters: User-selected trusted parties (requires mutual acceptance)

Possible Outcomes

Payer Wins: Full refund to payer(s)

Receiver Wins: Full release to receiver(s)

Split Decision: Proportional distribution based on arbiter ruling

All dispute proceedings and outcomes are recorded for compliance and audit purposes, with data retained according to regulatory requirements.

9. Fee Transparency

Our fee structure is designed to be transparent, fair, and compliant with consumer protection regulations.

Tiered Fee Structure

RangeFeeBPS
$0 - $1,0001.5%150 basis points
$1,001 - $25,0001.0%100 basis points
$25,001 - $100,0000.75%75 basis points
Over $100,0000.5%50 basis points

Fee Collection

  • Fees are collected at the time of deposit, not release
  • Fee calculation is transparent and verifiable on-chain
  • No hidden fees or charges beyond stated platform fees
  • Network gas fees are separate and paid directly to blockchain validators

Refund Policy

Platform fees are non-refundable once collected. This policy applies regardless of escrow outcome (completion, cancellation, expiry, or dispute). This prevents system abuse and ensures platform sustainability.

10. Multi-Chain Compliance

We deploy our smart contracts across multiple blockchain networks, maintaining consistent compliance standards on each.

Supported Networks

Ethereum MainnetPolygon (MATIC)Arbitrum OneOptimismBase

Cross-Chain Consistency

  • Identical smart contract code deployed across all chains
  • Same compliance standards regardless of network
  • Deterministic contract addresses for easy verification
  • Unified fee structure across all supported networks

We monitor regulatory developments specific to each blockchain network and implement any required compliance measures accordingly.

11. Prohibited Activities

To maintain regulatory compliance and platform integrity, certain activities are strictly prohibited.

Prohibited Uses

  • Money laundering, terrorist financing, or sanctions evasion
  • Transactions involving proceeds of crime or illegal activities
  • Circumvention of applicable laws or regulations
  • Use of anonymity-enhanced cryptocurrencies (prohibited under UAE VARA)
  • Market manipulation or fraudulent schemes
  • Activities that violate intellectual property rights
  • Transactions with sanctioned individuals, entities, or jurisdictions
  • Any activity that could harm the platform, other users, or the broader ecosystem

Violations may result in immediate account suspension, fund freezing (where legally required), and reporting to relevant authorities.

12. Future Regulatory Developments

The regulatory landscape for virtual assets continues to evolve. We are committed to staying ahead of regulatory changes.

Regulatory Monitoring

  • Continuous monitoring of FATF guidance and member country implementations
  • Tracking UAE regulatory developments (VARA, SCA, CBUAE)
  • Following EU developments including MiCA implementation and DAC8
  • Monitoring global regulatory trends and best practices

CARF (Crypto-Asset Reporting Framework)

The UAE has signed the Multilateral Competent Authority Agreement for CARF, with implementation expected from January 2027. We are preparing systems to support CARF reporting requirements.

We commit to adapting our compliance program as regulatory requirements evolve, ensuring continuous compliance without disruption to user services.

13. Compliance Contact

For compliance-related inquiries or to report concerns:

Elysium Media FZCO

Compliance Officer: [email protected]

AML/KYC Inquiries: [email protected]

Data Protection Officer: [email protected]

General Inquiries: [email protected]

Elysium Media FZCO, Dubai Digital Park, Dubai Silicon Oasis, United Arab Emirates

License No. 58510

TRN: 104956612600003

We maintain confidential channels for reporting compliance concerns. All reports are taken seriously and investigated appropriately.

Acknowledgment

By using VeriEscrow, you acknowledge that you understand our compliance framework and agree to use the platform in accordance with all applicable laws and regulations. You understand that VeriEscrow is a non-custodial platform and that compliance with local laws in your jurisdiction is your responsibility.