Escrow & Payments Policy

1.1 This Escrow & Payments Policy describes how Client Funds are held, released and refunded on the Platform, and which payment methods are available at pay-in and payout. It supplements the Terms of Service and the Refund & Dispute Policy.

1.2 It applies to every Order placed on the Platform.

2.1 Operator. Acts as a technical platform and commercial agent of the Seller for the receipt of Client Funds under the exclusion in Regulation 3 and Schedule 1, Part 2, paragraph (b) PSR 2017.

2.2 Payment Institution. [Payment Institution - Acquirer / EMI partner to be inserted] - an FCA / EEA-regulated payment or electronic-money institution that (i) safeguards Client Funds in a segregated safeguarding account, (ii) processes card and non-card pay-ins, (iii) executes payouts to Sellers, (iv) performs KYC, KYB, sanctions screening and transaction monitoring, (v) handles chargebacks and disputes with card issuers, and (vi) is the relevant person for MLR 2017 purposes.

2.3 Steam / game publisher. Operates the trade mechanism through which Items are transferred between game accounts. The Operator and Payment Institution have no control over Steam holds, mobile-authenticator delays or Steam trade bans.

3.1 Accepted pay-in methods

• Card - Visa, Mastercard, American Express (where available), Apple Pay, Google Pay - all with 3-D Secure 2 Strong Customer Authentication;
• SEPA Credit Transfer (EUR);
• UK Faster Payments / Open Banking (GBP);
• SWIFT (USD and other supported currencies).

3.2 Prohibited pay-in methods

• cash and cash-equivalents;
• cryptocurrency and stablecoins (not accepted by the Payment Institution);
• money-remittance services (Western Union, MoneyGram and similar);
• prepaid anonymous cards and virtual gift cards;
• third-party payments (a card or account in a name other than the Buyer's).

3.3 Name-Match rule. The Buyer must fund the Order from a payment instrument held in the Buyer's own name. Where the Payment Institution detects a name mismatch, the Order is cancelled and the funds are refunded to source.

3.4 Enhanced due diligence. Where a single Order, or the cumulative Orders of a Buyer, exceed EUR 15,000 (or its equivalent) within any twelve-month period, or where the Payment Institution flags an Order as high-risk, the Payment Institution may require enhanced due diligence, including source-of-funds documentation, before releasing escrow.

• Client Funds are held in the Payment Institution's safeguarded segregated account, ring-fenced from the Payment Institution's own funds and insolvency-remote as required by the applicable UK / EEA safeguarding rules.
• The Operator does not receive, hold, invest or otherwise deal with Client Funds. Interest, where any is earned, accrues to the Payment Institution and not to the Operator or to Users.
• Escrowed balances are shown on the User's dashboard for information only.

5.1 Release event. Escrow is released to the Seller upon (a) successful Item Transfer that matches the listing (see the Terms of Service, clause 6), (b) mutual cancellation of the Order in the Seller's favour, or (c) a dispute decision in the Seller's favour under the Refund & Dispute Policy.

5.2 Verified Payout Instrument (VPI) and Name-Match at payout. The Seller must maintain a Verified Payout Instrument - a bank account or debit / reloadable card in the Seller's own name, verified by the Payment Institution. The Operator does not release a payout to a payout instrument that is not name-matched to the Seller.

5.3 Supported payout methods

• SEPA Credit Transfer (EUR) - same day or next business day;
• UK Faster Payments (GBP) - typically within minutes on business days;
• SWIFT (USD and other supported currencies) - 1 to 4 business days;
• local ACH-equivalents in supported countries as offered by the Payment Institution;
• Card push-to-card top-up (payout to a debit or reloadable card) via Visa Direct / Mastercard Send - typically within minutes on supported cards. The receiving card must be a Verified Payout Instrument in the Seller's own name (see clause 5.2) and must be issued in a country supported by the Payment Institution for push-to-card payouts. Card push-to-card is not available for credit cards, prepaid anonymous cards, or virtual gift cards, and may be subject to additional per-transaction and daily push-to-card limits.

5.4 Payout timing and limits

• standard payout schedule - T+1 business day from the release event; immediate payouts on request for verified Sellers, subject to risk checks;
• card push-to-card top-up - typically credited within minutes on supported cards, subject to card-network processing and issuer rules;
• per-transaction, daily and monthly payout limits apply and are disclosed on the payout screen; separate lower limits may apply to card push-to-card payouts;
• a payout can be delayed where a chargeback, dispute, sanctions match, court order or tax hold applies.

5.5 Fees applied at payout. The Platform service fee, payment-processing fees, FX margin, withdrawal fees and card push-to-card fees are disclosed on the fee schedule and on the payout screen and are deducted from the amount released to the Seller.

5.6 Refunds. Refunds are made only to the payment instrument used to fund the escrow (return-to-source rule). Refunds are not paid to a different card, account or wallet. See the Refund & Dispute Policy for the full mechanics.

6.1 AML / CTF, sanctions screening and transaction monitoring are performed by the Payment Institution. The Operator supports the Payment Institution by (i) forwarding evidence requests to Users, (ii) suspending accounts on the Payment Institution's instruction, and (iii) enforcing anti-circumvention and prohibited-use rules under the Terms of Service.

6.2 The Operator is not a relevant person under MLR 2017 and does not itself run an AML programme. The Operator does not have an MLRO and does not file SARs on its own account. The Payment Institution files SARs to the NCA where applicable.

Chargebacks and reversals raised by a Buyer's card issuer or bank are handled by the Payment Institution using the dispute-defence pack the Operator maintains for each Order (Order log, Item Transfer evidence, IP logs, communications). Where a chargeback succeeds after payout, clause 13 of the Terms of Service applies.

Where a Seller balance remains inactive for twenty-four (24) months and the Seller does not respond to reminders sent to the last known contact address, the balance is treated in accordance with English rules on dormant balances and unclaimed property.

Escrow and payments queries: [email protected]. Complaints: [email protected]. Legal notices: [email protected].