Escrow Funding Supplemental Terms & Conditions

Legal Tender Services PLLC (‘LTS’) is committed to the highest standards of compliance with financial crime legislation and seeks to employ best practices to the fullest extent possible. These Terms & Conditions reflect a commitment to adherence to all applicable rules and regulations.

Accordingly, LTS does not knowingly accept into escrow any funds, including cash or cash equivalents (the cash economy being particularly susceptible to abuse by criminal actors and enterprises), which constitute in whole or in part the proceeds of any form of Unlawful Activity. In addition, LTS does not knowingly accept escrow deposits from, nor make escrow distributions to, any Blocked Person. Finally, LTS fully complies with financial transaction reporting requirements promulgated by the U.S. Department of the Treasury, including FinCEN, IRS, OCC and OFAC, as well as any other similar federal, state or local governmental agency.

In this document, certain words and phrases have special meanings as follows:

• “Blocked Person” means any individual or entity:

  1. listed on the Specially Designated Nationals and Blocked Persons List maintained by OFAC pursuant to Executive Order number 13224, 66 Federal Register 49079 (September 25, 2001) (the "Order");

  2. listed on any other list of terrorists or terrorist organizations maintained pursuant to the Order, the rules and regulations of OFAC or any other applicable requirement contained in any enabling legislation or other executive orders in respect to the Order (hereinafter collectively the "Orders");

  3. engaged in activities prohibited in the Orders; or

  4. convicted, pleaded nolo contendere, indicted, arraigned or detained on charges involving money laundering or predicate crimes to money laundering.

• “FinCen" means the United States Financial Crimes Enforcement Network.

• “IRS” means the Internal Revenue Service.

• “OCC” means Office of the Comptroller of the Currency.

• “OFAC” means the Office of Foreign Asset Control.

• “Unlawful Activity” includes, but is not limited to:

  • computer crimes, including ransomeware and identity theft;

  • extortion, blackmail and bribery;

  • financial crimes, including any act or omission violative of:

    1. the United States Bank Secrecy Act, 31 USC §§ 5311 - 5332;

    2. The Orders by which the Specially Designated Nationals and Blocked Persons List is maintained by OFAC; and

    3. any other similar statute or regulation of the United States;

  • forgery and counterfeiting;

  • fraud, including charge card, wire, insurance and tax fraud, embezzlement, check kiting and the like.

  • import/export criminal violations;

  • kidnap and ransom;

  • larceny, including grand and petty theft, armed and unarmed robbery, burglary, looting, shoplifting, and receiving stolen property;

  • money laundering, including the movement of illicit cash or cash equivalent proceeds into, out of, or through the United States, or into, out of, or through United States financial institutions;

  • pornography, prostitution, and human trafficking,

  • poaching or trafficking in endangered or regulated species;

  • rioting, terrorism and terrorist funding;

  • securities law violations and pyramid schemes;

  • tax evasion, including the promotion of abusive tax shelters;

  • treason, espionage; and

  • unauthorized production or distribution of narcotic drugs or controlled substances, including marijuana having a delta-9 tetrahydrocannabinol concentration of more than 0.3 percent on a dry weight basis.

LTS employs its best efforts to process escrow transactions timely, bearing in mind that certain forms of escrow deposits, such as valid and legitimate cash, cash equivalents and crypto currencies, may require a longer time to process than others. LTS reserves the right to update and amend these Terms & Conditions from time to time in order to reflect changing circumstances and developing regulatory requirements.