Escrow & Payment Protection Terms
AqNova Marketplace Policies & Disclosures
AQNOVA MARKETPLACE
Global Legal Footer Framework
Comprehensive Compliance & Platform Governance Reference
(MASTER)
Complete Disclosure of AqNova's Payment Holding, Escrow Mechanics, Release Triggers, Dispute-Hold Procedures & Global Regulatory Compliance
Effective Date: April 7, 2026 | Version 1.0 | Arivon Holding Corporation
| Regulatory & Legal Frameworks — Escrow & Payment Protection United States: Electronic Fund Transfer Act (EFTA, 15 U.S.C. § 1693) Fair Credit Billing Act (FCBA, 15 U.S.C. § 1666) Dodd-Frank Wall Street Reform Act — CFPB oversight California Escrow Law (Cal. Fin. Code § 17000 et seq.) California Money Transmission Act (Cal. Fin. Code § 2030) New York Banking Law — money transmission licensing FinCEN Money Services Businesses (31 C.F.R. Part 1022) OFAC — sanctions screening in payment processing European Union: EU Payment Services Directive 2 (PSD2, 2015/2366/EU) EU E-Money Directive (2009/110/EC) EU Interchange Fee Regulation (2015/751/EU) EU Electronic Commerce Directive (2000/31/EC) GDPR — payment data processing obligations United Kingdom: Payment Services Regulations 2017 (SI 2017/752) — PSD2 UK Electronic Money Regulations 2011 (SI 2011/99) FCA Payment Institution authorization requirements Financial Services and Markets Act 2000 (FSMA 2000) Canada: Payment Card Networks Act | Retail Payment Activities Act (RPAA) FINTRAC — money services business registration FCAC (Financial Consumer Agency of Canada) — payment protections Brazil: BACEN Resolution 4,649/2018 (Payment Institutions) BACEN Resolution 4,282/2013 (Online Marketplace Payments) Arranjos de pagamento — payment arrangement authorization Pix Regulations (BACEN Resolution 4,697/2020) Nigeria: CBN Guidelines on Electronic Payments (various circulars) PSB (Payment Service Bank) licensing requirements CBN Regulations on e-Commerce Escrow South Africa: National Payment System Act 78 of 1998 (NPSA) SARB Payment System Management Body (PSMB) Banks Act 94 of 1990 — banking regulation India: Payment and Settlement Systems Act 2007 (PSSA) RBI Guidelines on Escrow Mechanism for Online Marketplaces (RBI/2019-20/221 P.S.S. Circular 04/2020-21) RBI Master Directions — Payment Aggregators and Gateways Australia: Payment Systems (Regulation) Act 1998 | ePayments Code (ASIC) National Consumer Credit Protection Act 2009 (NCCP) Australian Prudential Regulation Authority (APRA) oversight Singapore: Payment Services Act 2019 (PSA) — MAS licensing MAS Guidelines on Digital Payment Token Services Japan: Fund Settlement Act (Shikin Kessei Ho) Payment Services Act (Shiharai Sabisu Ho) South Korea: Electronic Financial Transactions Act (EFTA-KR) Financial Services Commission (FSC) / Financial Intelligence Unit China: Non-Bank Payment Institution Regulation (PBOC, 2023) People's Bank of China (PBOC) payment system oversight E-Commerce Law 2019 (Arts. 58–59) — consumer payment guarantee Colombia / Chile / Argentina / Mexico: National payment services and consumer laws International: FATF Recommendations — AML/CFT for payment institutions PCI DSS — Payment Card Industry Data Security Standard |
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| IMPORTANT NOTICE AQNOVA HOLDS BUYER PAYMENTS IN AN INTERNAL PAYMENT HOLDING MECHANISM (REFERRED TO AS 'ESCROW' IN THIS DOCUMENT FOR SIMPLICITY) OPERATED THROUGH LICENSED PAYMENT PROCESSORS. AQNOVA IS NOT A LICENSED ESCROW COMPANY OR BANK. FUNDS ARE HELD BY AQNOVA'S PAYMENT PROCESSORS — NOT IN A DEDICATED ESCROW ACCOUNT IN THE TRADITIONAL LEGAL SENSE — PENDING RELEASE TO VENDORS. THIS MECHANISM PROTECTS BUYERS BY ENSURING VENDORS ARE PAID ONLY AFTER CONFIRMED DELIVERY AND EXPIRY OF THE BPP CLAIM WINDOW. APPLICABLE REGULATORY REQUIREMENTS IN EACH JURISDICTION ARE DISCLOSED BELOW. |
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This Escrow & Payment Protection Terms document ("Escrow Policy") provides the complete disclosure of AqNova's payment holding and release mechanism, which protects Buyers and Vendors by ensuring that Buyer payments are released to Vendors only upon confirmed delivery and the expiry of any applicable Buyer Protection claim window. This Escrow Policy supplements and should be read in conjunction with the Buyer Protection Policy (Section 5.2), the Dispute Resolution Policy (Section 5.3), and the Pricing & Payments Policy (Section 4.4).
AqNova uses the term "escrow" throughout this document as a simplified description of its payment holding mechanism. The technical payment structure involves AqNova holding unremitted Vendor payout balances within its payment processor accounts — pending the release triggers described below — rather than operating a traditional third-party escrow account. This distinction is important for regulatory purposes: AqNova is not a licensed escrow company in any jurisdiction, and the protections provided by this mechanism arise from contract and payment processor account structure, not from escrow law per se.
| Section 5.4 — Structure 5.4.1 What Is the AqNova Escrow Mechanism? 5.4.2 How Funds Are Held — Payment Processor Structure 5.4.3 Escrow Trigger Events — When Does Holding Begin? 5.4.4 Escrow Release Triggers — When Are Funds Released to the Vendor? 5.4.5 Dispute-Hold Procedures — Funds Held Pending BPP/Dispute Resolution 5.4.6 Payout Reserve — Long-Term Protection Holding 5.4.7 AML & Compliance Holds — Regulatory-Triggered Payment Holds 5.4.8 Escrow for High-Value Transactions 5.4.9 Escrow and Subscription / Recurring Payments 5.4.10 Regional Regulatory Requirements for Payment Protection 5.4.11 Payment Processor Partners & Their Role 5.4.12 Buyer Rights — What Escrow Means for the Buyer 5.4.13 Vendor Rights — What Escrow Means for the Vendor 5.4.14 Escrow in Insolvency — What Happens if AqNova Ceases Operations 5.4.15 Contact Information — Escrow & Payment Protection |
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5.4.1 What Is the AqNova Escrow Mechanism?
AqNova's payment protection mechanism works as follows: when a Buyer places an order and payment is captured at checkout, the payment is processed through AqNova's payment processor (Stripe, Adyen, PayPal, or applicable regional processor). The payment is credited to AqNova's merchant account. AqNova then records the Vendor's share of that payment — the purchase price less AqNova's commission — as a "pending payout" in the Vendor's payout account within the AqNova Platform. This pending payout is not remitted to the Vendor until the applicable release trigger is met.
The mechanism operates through AqNova's payout management system, which tracks the status of every pending payout and applies the appropriate hold or release logic based on the order status, delivery confirmation, Buyer feedback, and any active disputes. The net effect is that Vendor payouts are held within AqNova's payment infrastructure — protected from premature remittance — until the Buyer's interests are adequately protected.
| AqNova Escrow Mechanism — Key Characteristics NOT A TRADITIONAL ESCROW ACCOUNT: Funds are not held in a dedicated client money account or statutory escrow account. They are held within AqNova's payment processor accounts as pending payouts. AqNova is not a licensed escrow company or trust company. OPERATED THROUGH LICENSED PAYMENT PROCESSORS: All payment handling is conducted by PCI-DSS Level 1 certified payment processors (Stripe, Adyen, PayPal, and regional equivalents). These processors are licensed payment institutions in their respective jurisdictions. CONTRACTUAL PROTECTION, NOT STATUTORY ESCROW PROTECTION: The protection provided to Buyers arises from: (a) AqNova's contractual commitment to hold Vendor payouts pending the release triggers; (b) the Buyer Protection Program's guarantee to refund from payout reserves; and (c) the payment processor's technical payout management infrastructure. BENEFIT TO BUYERS: Ensures Vendors are not paid until delivery is confirmed and the BPP claim window has passed, preserving AqNova's ability to fund BPP refunds. BENEFIT TO VENDORS: Provides predictable, transparent payout timelines. Vendor payouts are not subject to arbitrary hold beyond defined release triggers. |
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5.4.2 How Funds Are Held — Payment Processor Structure
The technical structure of AqNova's payment holding mechanism operates through the following layers:
A. Payment Capture Layer
When a Buyer pays for an order, payment is captured by AqNova's payment processor (e.g., Stripe) into AqNova's merchant account. At this point:
The Buyer's payment instrument has been charged. The Buyer sees a debit on their account.
The funds are held in AqNova's payment processor account, not yet disbursed to anyone.
AqNova's platform records the transaction and credits the applicable Vendor's pending payout balance.
B. Pending Payout Layer
The "pending payout" is AqNova's internal accounting record of how much of the captured funds belong to the Vendor (after deduction of AqNova's commission). This pending payout:
Is visible to the Vendor in their Vendor Dashboard in real time.
Is held by AqNova pending the applicable release trigger.
Is funded from AqNova's payment processor balance — not from a dedicated segregated client account.
Is not a debt owed by AqNova to the Vendor until the release trigger is met — it is a conditional obligation.
C. Reserve Layer
A portion of each Vendor's accumulated pending payout balance is designated as a "payout reserve" — a buffer maintained to fund potential BPP claims, chargeback liabilities, and AML compliance holds. The payout reserve:
Is deducted from the total pending payout before the standard escrow release.
Is held for the applicable reserve period (minimum 14 days for new Vendors; 7 days for established Vendors with clean performance history).
Is released to the Vendor in the next payout cycle after the reserve period expires, unless a claim or compliance hold is active.
5.4.3 Escrow Trigger Events — When Does Holding Begin?
The payment holding mechanism activates at Order Confirmation — the moment AqNova sends the Buyer an Order Confirmation email, which is also the moment the purchase contract is formed between the Buyer and Vendor. From Order Confirmation:
| Escrow Trigger Events — Timeline from Order Confirmation ORDER CONFIRMATION (T=0): Payment captured by payment processor. Vendor pending payout credited in Vendor Dashboard. Escrow / payment holding period BEGINS. Escrow status: ACTIVE — funds withheld from Vendor. DISPATCH + TRACKING UPLOADED (T = dispatch date): Vendor confirms dispatch and uploads tracking number. Escrow status: ACTIVE — funds still withheld. BPP claim window begins when the estimated delivery date passes. CONFIRMED DELIVERY (T = delivery date): Carrier confirms delivery (scan event at delivery point). OR Buyer confirms delivery manually. 14-day automatic release countdown begins. Escrow status: APPROACHING RELEASE. 14 CALENDAR DAYS AFTER CONFIRMED DELIVERY (T = delivery + 14 days): If no BPP claim has been filed: AUTOMATIC RELEASE TRIGGER activated. If a BPP claim is active: escrow remains on hold. Escrow status (no claim): RELEASED — Vendor payout processed. Escrow status (active claim): DISPUTE HOLD — see Section 5.4.5. BUYER CONFIRMATION OF RECEIPT (earlier than 14-day automatic): Buyer marks order as received and satisfactory in My Orders. OR Buyer submits a positive review for the order. IMMEDIATE RELEASE TRIGGER activated (within 24 hours). Escrow status: RELEASED — Vendor payout processed within 24 hours. |
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A. No-Tracking Scenario
Where a Vendor fails to upload tracking information within 48 hours of the stated dispatch window, the 14-day automatic release countdown does not begin. The escrow remains active indefinitely until either:
The Vendor uploads valid tracking information (countdown begins upon upload).
The Buyer files a BPP INR claim (dispute hold activates).
The Buyer confirms receipt (immediate release trigger).
Vendors are strongly incentivized to upload tracking promptly: indefinite escrow hold delays their payout. Consistent failure to upload tracking is a performance violation under the Vendor Agreement.
B. Pre-Order & Back-Order Escrow
For pre-orders and back-orders (where dispatch is delayed beyond the standard processing window), the escrow is active from payment capture and the 14-day countdown begins only upon actual confirmed delivery — not from the original estimated delivery date. Pre-order Buyers are protected throughout the potentially extended fulfillment period.
5.4.4 Escrow Release Triggers — When Are Funds Released to the Vendor?
Escrow release occurs upon the earliest of the following three triggers, subject to the absence of any active dispute hold, compliance hold, or reserve hold:
| Release Trigger | Conditions & Mechanics |
|---|---|
| TRIGGER 1 — Buyer Confirmation (Earliest Release) | The Buyer actively marks the order as satisfactorily received through: My Orders > [Order] > Confirm Receipt. OR The Buyer submits a positive review (3 stars or above) for the purchased product. EFFECT: Funds released to Vendor within 24 hours of confirmation event. This is the fastest route to Vendor payout — AqNova encourages Vendors to remind Buyers to confirm receipt where the buyer experience has been positive. Vendors may not pressure, incentivize, or coerce Buyers into confirming receipt prematurely. |
| TRIGGER 2 — 14-Day Automatic Release (Standard) | If the Buyer has not filed a BPP claim AND has not disputed delivery within 14 calendar days of the confirmed delivery date (carrier delivery scan), funds are automatically released. CALCULATION: 14 calendar days from the date of the carrier's confirmed delivery event. If delivery is confirmed on April 7, automatic release occurs on April 21. EFFECT: Funds released in the next scheduled payout cycle after the 14-day window expires. Payout cycles run weekly (standard). RATIONALE: 14 days gives the Buyer adequate time to inspect the goods and raise any issues, while ensuring the Vendor does not face indefinite holding. The 14-day period aligns with the EU Consumer Rights Directive's 14-day withdrawal period — a consumer who has not raised any issue within 14 days of delivery has indicated, by their conduct, satisfaction with the goods. |
| TRIGGER 3 — BPP Claim Resolution (Favoring Vendor) | If a BPP claim was filed and the investigation concluded in the Vendor's favor (claim not upheld; Buyer withdrew claim; claim outside BPP scope), funds are released within 24 hours of the BPP decision notification to the Vendor. This trigger releases funds that were under dispute hold. EFFECT: Immediate payout to Vendor upon favorable BPP decision (subject to reserve holding, if applicable). AqNova notifies the Vendor by email of the payout release. |
A. Partial Order Releases
For multi-item orders where individual line items have different delivery dates or statuses, AqNova supports line-item level escrow release. Where one item from a multi-item order has been confirmed delivered and its 14-day window has expired without a dispute, AqNova releases the escrow for that specific line item, even if other line items from the same order are still in transit. This prevents a Vendor from having their entire multi-item order payment held because one item has a delivery delay.
5.4.5 Dispute-Hold Procedures — Funds Held Pending BPP/Dispute Resolution
When a Buyer files a BPP claim or escalates a dispute to AqNova mediation (Tier 2 or Tier 3 of the Dispute Resolution process), a dispute hold is activated on the applicable Vendor's pending payout for the disputed transaction. The dispute hold:
Prevents the automatic 14-day release trigger from operating while the dispute is active.
Ensures that funds are available to fund a Buyer refund if the BPP claim is upheld.
Is applied only to the specific pending payout amount attributable to the disputed order — not to the Vendor's entire payout balance.
A. Dispute Hold Lifecycle
| Dispute Hold — Lifecycle and Resolution ACTIVATION: Dispute hold activates automatically when: — A BPP claim is filed through My Orders > Open Dispute; OR — AqNova initiates a dispute hold at its own discretion (e.g., fraud alert, safety concern, chargeback notification). DURING THE HOLD: — Specific order payout is withheld from Vendor's next payout cycle. — Hold amount is visible in Vendor Dashboard as 'Disputed Hold.' — Vendor may continue receiving payouts for other non-disputed orders. — Hold does not affect Vendor's other listings or account status (unless the dispute reveals a serious policy violation). RESOLUTION — BUYER'S FAVOR (Claim Upheld): — AqNova issues Buyer refund from the held funds within 24 hours of the BPP decision. — Vendor payout for the disputed order is fully or partially reduced by the refund amount. — If held funds are insufficient: AqNova uses Vendor payout reserve. RESOLUTION — VENDOR'S FAVOR (Claim Not Upheld): — Dispute hold released within 24 hours of the BPP decision. — Full disputed payout amount released to Vendor in the next payout cycle. RESOLUTION — PARTIAL (Partial Refund): — BPP partial refund issued to Buyer from held funds. — Remaining held amount (after partial refund) released to Vendor. MAXIMUM HOLD DURATION: — Standard BPP investigation: 10 Business Days. — Complex/high-value: 20 Business Days. — If resolution is extended beyond 20 Business Days: both Buyer and Vendor are notified with a new expected resolution date. — AML / Compliance holds: up to 60 calendar days (see Section 5.4.7). — Court orders or regulatory holds: indefinite, until the order is lifted. |
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B. Chargeback Dispute Hold
Where AqNova receives a chargeback notification from a payment network or card issuer, a dispute hold is automatically activated on the relevant Vendor's payout for the charged-back transaction, pending:
AqNova's review of the chargeback validity (legitimate or abusive).
Submission of AqNova's chargeback response package to the payment network (where the chargeback is disputed by AqNova).
Receipt of the payment network's chargeback decision.
Chargeback resolution timelines are governed by the applicable card network rules and are outside AqNova's direct control. AqNova notifies the Vendor of the chargeback and the hold amount within 2 Business Days of receiving the chargeback notification. AqNova provides the Vendor with the opportunity to submit evidence for AqNova's chargeback defense within 5 Business Days.
5.4.6 Payout Reserve — Long-Term Protection Holding
In addition to the transaction-specific escrow mechanism, AqNova maintains a payout reserve — a rolling buffer of held funds from each Vendor's payout — to ensure that AqNova can fund BPP refunds, chargeback liabilities, and applicable compliance holds without delay, even for transactions whose 14-day escrow window has already passed.
A. Payout Reserve Structure
| Vendor Category | Reserve Rate & Release Schedule |
|---|---|
| New Vendors (first 90 days of active selling) | 20% of each weekly payout is held in reserve for 14 calendar days. After 14 days: released in the next weekly payout cycle (assuming no active claims). Rationale: new Vendors present higher fraud and non-performance risk. The 14-day reserve provides an additional window for BPP claims to materialize. |
| Established Vendors (90+ days, clean performance) | 10% of each weekly payout held in reserve for 7 calendar days. Released in the following weekly payout cycle. Performance criteria: late dispatch rate below 2%; BPP claim rate below 1%; no active enforcement actions. |
| High-Risk Vendors (elevated BPP claim rate, prior enforcement) | 25% of each weekly payout held for 21 calendar days. AqNova notifies the Vendor when elevated reserve status is applied and the criteria for returning to standard reserve levels. |
| Vendors Under Investigation (active Trust & Safety investigation) | 100% payout hold for the duration of the investigation (up to 60 calendar days). AqNova notifies the Vendor immediately. Payouts resume at standard reserve level upon clearance. |
| Vendors in Account Termination (departing Vendors) | 60-day final reserve hold on all outstanding payouts to cover final BPP claims and chargeback rights. After 60 days: remaining payout released (less any deductions for confirmed claims) to the Vendor's registered bank account. |
B. Payout Reserve Transparency
AqNova provides full transparency on payout reserves to Vendors through the Vendor Dashboard:
Reserved Amount: the total reserve currently held, visible in real time in Vendor Dashboard > Payouts > Reserve Status.
Release Schedule: the date on which each tranche of the reserve is expected to be released, if no claims are filed.
Active Hold Reason: where a reserve hold is elevated due to an investigation or enforcement action, the Vendor is notified by email with the reason and expected hold duration.
Reserve History: a full history of reserve holds, releases, and deductions is available for download from the Vendor Dashboard.
5.4.7 AML & Compliance Holds — Regulatory-Triggered Payment Holds
In addition to BPP dispute holds and payout reserves, AqNova may apply compliance-driven payment holds where required by applicable law or its own AML/CTF (Anti-Money Laundering / Counter-Terrorist Financing) program. Compliance holds are entirely separate from dispute holds and are not subject to the BPP timelines.
A. Grounds for AML/Compliance Holds
Sanctions screening match: a pending payout involves a Vendor entity or beneficial owner that has been identified as a potential match on an OFAC, EU, UN, or OFSI sanctions list. The hold continues until the match is cleared (confirmed as a false positive) or referred to the applicable authority.
Suspicious Activity Report (SAR) filing: where AqNova is required to file a SAR with FinCEN (US), NCA (UK), COAF (Brazil), NFIU (Nigeria), FIC (South Africa), or applicable FIU, it may be required to freeze the associated funds pending the outcome of any law enforcement inquiry.
Court order or regulatory freeze: where a court or regulatory authority issues an order requiring AqNova to freeze funds associated with a specific Vendor account, AqNova complies immediately.
KYC/identity verification failure: where a Vendor fails to complete required identity re-verification within the specified timeframe, payout is held until verification is completed.
Structuring patterns: where a Vendor's transaction patterns suggest structuring (breaking transactions into amounts below reporting thresholds) or other AML indicators, payout may be held pending enhanced due diligence.
B. Compliance Hold Timelines
| Hold Type | Maximum Hold Duration & Resolution Path |
|---|---|
| Sanctions match (unresolved) | Held indefinitely until match is cleared or referred. AqNova notifies the Vendor that a hold is in place (but may not be able to disclose the specific reason if required by SAR non-disclosure rules / 'tipping off' prohibition). |
| SAR-related hold | Held for up to 60 calendar days pending law enforcement response. If no law enforcement action within 60 days: hold reviewed and either extended with documented justification or released. |
| Court order / regulatory freeze | Held for the duration of the court order or regulatory instruction. AqNova provides the Vendor with a copy of the order upon receipt. |
| KYC failure hold | Held until verification is completed, subject to a maximum of 90 calendar days. After 90 days without KYC completion: account suspended and payout held pending account resolution process. |
| AML pattern / enhanced DD | Held for up to 30 calendar days while enhanced due diligence is conducted. Vendor may be required to provide source-of-funds documentation. If EDD passes: hold released. If EDD fails: SAR process initiated. |
C. Non-Disclosure Restrictions
In cases where AqNova has filed or is in the process of filing a SAR, AqNova may be legally prohibited from disclosing to the Vendor the existence of the SAR or the specific reason for a payout hold (the "tipping off" prohibition under the Bank Secrecy Act in the US (31 U.S.C. § 5318(g)(2)), the Proceeds of Crime Act 2002 in the UK (s. 330), the Financial Intelligence Centre Act in South Africa, and equivalent AML laws). In those cases, AqNova will notify the Vendor that a compliance hold is in place and that AqNova is unable to provide further information about the reason at this time.
5.4.8 Escrow for High-Value Transactions
Transactions above USD $5,000 (or equivalent in local currency) are subject to enhanced escrow provisions in addition to the standard 14-day release mechanism:
Extended automatic release: for high-value transactions, the automatic release trigger is extended to 21 calendar days from confirmed delivery (rather than 14 days), to allow additional time for inspection, BPP claims, and authentication verification.
Mandatory proof of delivery: high-value transactions require electronic proof of delivery (GPS confirmation, signature scan, or photo confirmation of delivery) before the automatic release countdown begins. Standard "delivered" scan events without supplementary POD are insufficient.
Escrow verification for above USD $10,000: for transactions above USD $10,000 (or equivalent), the Vendor's payout is subject to an additional 24-hour manual review by AqNova's Finance team before release, to verify the transaction's legitimacy and compliance with applicable payment regulations.
High-value payout limits: AqNova may impose daily payout limits per Vendor to manage fraud risk. Vendors who need to receive large single-transaction payouts should contact vendors@aqnova.co to arrange appropriate payout processing.
5.4.9 Escrow and Subscription / Recurring Payments
Subscription and recurring payment products have specific escrow characteristics that differ from single-transaction purchases:
Each billing cycle payment is treated as a separate transaction for escrow purposes. A subscription's monthly charge on April 1 has a separate 14-day escrow window from the charge on May 1.
No cumulative escrow: AqNova does not hold subscription payments cumulatively across billing cycles. Each cycle's payment enters and exits the escrow mechanism independently.
Dispute hold on subscription cancellation: where a subscriber cancels a subscription and disputes a recent charge, the disputed billing cycle's payment is placed under dispute hold while the cancellation/refund dispute is resolved under the Cancellation Policy (Section 4.3.9) and BPP.
BNPL and installment plans: individual installment payments under a BNPL or installment arrangement are each treated as separate payments for escrow tracking. The escrow for each installment is active from the installment capture date and is released (for the applicable installment amount) upon the standard release trigger.
5.4.10 Regional Regulatory Requirements for Payment Protection
The following table summarizes the jurisdiction-specific regulatory requirements that inform AqNova's payment protection and escrow framework:
| Jurisdiction / Regulatory Framework | Applicable Requirements & AqNova's Compliance Approach |
|---|---|
| United States — EFTA / FCBA / FinCEN | EFTA governs unauthorized electronic fund transfers — Buyer disputes are processed within applicable EFTA timelines. FCBA governs billing disputes for credit card transactions. FinCEN MSB registration: AqNova's payment processors are licensed money services businesses or payment processors registered with FinCEN. AqNova itself is not a money transmitter. California Money Transmission Act: AqNova evaluates its payment activities against California Fin. Code § 2030 and does not conduct unlicensed money transmission. |
| European Union — PSD2 / E-Money Directive | PSD2 (2015/2366/EU) regulates payment services in the EU. AqNova's payment processors (Stripe Europe, Adyen BV, PayPal Europe) are licensed Payment Institutions or Electronic Money Institutions under PSD2. AqNova's payout management function may constitute a payment service subject to PSD2 in some Member States. AqNova monitors and complies with applicable PSD2 obligations through its payment processor relationships. Strong Customer Authentication (SCA) under PSD2 Art. 97 is applied to all EU consumer card transactions. |
| United Kingdom — PSR 2017 / FCA | UK Payment Services Regulations 2017 (implementing PSD2 in UK) apply to AqNova's UK payment processing activities. AqNova's payment processors (Stripe UK, PayPal UK, Adyen) are FCA-authorized payment institutions. AqNova reviews its UK payment activities against the FCA's Consumer Duty and payment services regulatory framework. |
| Canada — RPAA / FINTRAC | Retail Payment Activities Act (RPAA): AqNova's payment processing activities in Canada are assessed against the RPAA framework. AqNova evaluates whether it is required to register as a payment service provider with the Bank of Canada under the RPAA. FINTRAC: AqNova's AML obligations in Canada include registration with FINTRAC as a money services business (if applicable based on activities) and compliance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act. |
| Brazil — BACEN Payment Institutions | BACEN Resolution 4,649/2018 regulates payment institutions in Brazil. BACEN Resolution 4,282/2013 addresses online marketplace payment flows. AqNova's Brazilian payment processing is conducted through BACEN-authorized payment institutions (Pagar.me, PagSeguro, Mercado Pago, or equivalent). PIX payments: governed by BACEN Resolution 4,697/2020. AqNova's escrow mechanism for Brazilian transactions complies with BACEN guidance on marketplace payment segregation. |
| Nigeria — CBN Payment System | CBN Guidelines on Electronic Payments and eNaira; PSB licensing requirements. AqNova's Nigerian mobile money and card payment processing is conducted through CBN-licensed payment service providers. CBN escrow regulations for marketplaces: AqNova's payout hold mechanism is structured to be consistent with CBN guidance on marketplace escrow for consumer protection. |
| India — RBI Escrow Guidelines | RBI/2019-20/221 P.S.S. Circular 04/2020-21 and RBI Master Directions on Payment Aggregators and Payment Gateways (March 2020): AqNova's Indian payment processing is conducted through RBI-authorized payment aggregators. The RBI's escrow requirement mandates that payment aggregators hold merchant settlement funds in designated nodal accounts until completion of the service/delivery. AqNova's mechanism, operated through its authorized payment aggregator, complies with this RBI escrow requirement. This is the most prescriptive mandatory escrow requirement applicable to AqNova globally. |
| South Korea — EFTA-KR | Electronic Financial Transactions Act (EFTA-KR) regulates electronic payment services. E-Commerce Consumer Protection Act mandates escrow or payment guarantee for internet shopping malls meeting defined criteria. AqNova's escrow mechanism satisfies South Korea's mandatory consumer payment guarantee requirement. AqNova's Korean payment processing is conducted through FSC-registered payment processors. |
| China — PBOC Non-Bank Payment Institution Regulation | PBOC Non-Bank Payment Institution Regulation 2023 governs third-party payment service providers in China. E-Commerce Law 2019 Arts. 58–59: consumer payment guarantee mechanism — AqNova's escrow framework provides the equivalent protection required under the E-Commerce Law. AqNova's Chinese payment processing is conducted through PBOC-licensed third-party payment providers (Alipay, WeChat Pay, or equivalent). |
| Singapore — PSA 2019 (MAS) | Payment Services Act 2019 (PSA): AqNova evaluates its Singapore payment activities against PSA licensing requirements. AqNova's Singapore payment processing uses MAS-licensed major payment institutions. MAS Digital Payment Token guidance: AqNova complies where cryptocurrency payment options are offered. |
| Australia — ASIC ePayments Code | ASIC's ePayments Code provides consumer protections for unauthorized electronic payments and error transactions. AqNova's payment processing complies with ePayments Code standards for error resolution and unauthorized transaction liability. APRA oversight applies to AqNova's banking and payment processor partners. |
| Japan — Fund Settlement Act | Fund Settlement Act (Shikin Kessei Ho): businesses handling third-party payment funds above JPY 10 million annually may require registration as a Fund Transfer Service Provider. AqNova monitors its Japanese payment activities against this threshold. Payment Services Act: AqNova uses licensed payment service providers for Japanese consumer transactions. |
5.4.11 Payment Processor Partners & Their Role
AqNova's escrow and payment protection mechanism is operated through its licensed Payment Processor partners. These partners are not mere technology vendors — they are regulated financial institutions that hold the actual funds between payment capture and Vendor payout. AqNova's relationship with its payment processors is governed by separate processing agreements that include the payment holding and release mechanics described in this Policy.
A. Principal Payment Processor Partners
| Processor / Region | Regulatory Status & Role in AqNova's Escrow Mechanism |
|---|---|
| Stripe (Global — primary processor) | Stripe, Inc. (US): registered with FinCEN as a Money Services Business; licensed money transmitter in applicable US states. Stripe Payments UK Ltd: FCA-authorized payment institution (FRN 900461). Stripe Technology Europe Ltd: Central Bank of Ireland-authorized payment institution. Stripe holds AqNova's merchant funds and manages payout disbursements. PCI-DSS Level 1 certified. |
| Adyen (Global — enterprise processing) | Adyen N.V.: licensed as an Electronic Money Institution (EMI) by De Nederlandsche Bank (DNB) in the Netherlands under the EU E-Money Directive. Adyen operates across the EU, UK, US, and globally. Adyen holds enterprise-level merchant funds and processes cross-border payouts for AqNova's high-volume Vendor accounts. |
| PayPal (Digital Wallet & Select Markets) | PayPal, Inc.: licensed money transmitter in applicable US states; FCA-authorized EMI (UK); regulated across EU and globally. PayPal Buyer Protection applies independently to PayPal-processed transactions. PayPal operates its own parallel escrow mechanism for PayPal-processed orders. |
| Pagar.me / Mercado Pago (Brazil) | Pagar.me: BACEN-authorized payment institution (IP/Arranjo de Pagamento). Mercado Pago: BACEN-authorized payment institution. These processors hold AqNova's Brazilian merchant funds and manage PIX, card, and boleto transactions. |
| Razorpay / PayU (India) | Razorpay Software Pvt Ltd: RBI-authorized payment aggregator. PayU Finance India Pvt Ltd: RBI-authorized payment aggregator. Both operate under the RBI Master Directions on Payment Aggregators. These processors hold AqNova's Indian merchant funds in designated nodal accounts as required by RBI. |
| Flutterwave / Paystack (Africa) | Flutterwave Inc: licensed across multiple African jurisdictions including Nigeria (CBN), Kenya (CBK), South Africa (FSB/FSCA). Paystack (Stripe subsidiary): CBN-licensed payment service provider in Nigeria. These processors enable AqNova's African payment processing and payout infrastructure. |
| Alipay / WeChat Pay / UnionPay (China, APAC) | Alipay (Ant Group): PBOC-licensed third-party payment service provider. Tencent Financial Technology (WeChat Pay): PBOC-licensed payment service. China UnionPay: Chinese national card network regulated by PBOC. These processors handle AqNova's Chinese consumer transactions under PBOC oversight. |
| Regional Processors (Other Markets) | AqNova uses additional regional payment processors for specific markets including: Klarna (BNPL, EU/UK/US), Afterpay/Clearpay (BNPL), PayNow/DBS (Singapore), M-Pesa/Safaricom API (Kenya), MTN MoMo API (West Africa), Interac e-Transfer (Canada). All regional processors are regulated by applicable national payment authorities. |
B. Relationship Between AqNova and Payment Processors
AqNova's payment processors hold the funds; AqNova instructs the processors on when and how to disburse those funds based on the release triggers described in this Policy. This instruction relationship is governed by AqNova's processing agreements with each processor. Buyers and Vendors do not have a direct legal relationship with AqNova's processors for the purposes of the escrow mechanism — their rights and protections arise from AqNova's obligations under this Policy, the BPP, and applicable consumer protection law.
5.4.12 Buyer Rights — What Escrow Means for the Buyer
The escrow mechanism is designed primarily to protect Buyers. From the Buyer's perspective, the key implications are:
| What Escrow Protection Means for Buyers — Key Rights 1. YOUR PAYMENT IS PROTECTED UNTIL DELIVERY IS CONFIRMED: The Vendor does not receive your payment until your goods are confirmed delivered and 14 days have passed without dispute. This means AqNova retains the ability to fund a refund from the held funds throughout the BPP claim window. 2. IF THE VENDOR DOESN'T DELIVER, AQNOVA CAN REFUND YOU FROM HELD FUNDS: For INR (non-delivery) claims within the escrow window, AqNova funds the refund from the Vendor's held payout — the money has not yet left AqNova's system. This is faster and more reliable than recovering funds from a Vendor who has already been paid. 3. THE 14-DAY WINDOW IS YOUR INSPECTION PERIOD: 14 calendar days from delivery is your window to inspect the goods and raise any BPP claim before funds are automatically released. Use this time to inspect your purchase carefully. 4. CONFIRMING RECEIPT IS VOLUNTARY — NO PRESSURE: You may confirm receipt early (to help the Vendor get paid faster) but you are never required to confirm receipt before you are satisfied. AqNova prohibits Vendors from pressuring Buyers to confirm receipt early. 5. ESCROW PROTECTION COMPLEMENTS YOUR STATUTORY RIGHTS: The escrow mechanism is an additional protection on top of your statutory consumer rights. Your legal rights (EU 2-year conformity guarantee; UK CRA 2015; ACL; etc.) are fully preserved regardless of escrow status. 6. IF A DISPUTE HOLD IS ACTIVE, YOUR REFUND IS SECURED: Once a BPP dispute hold is activated, the disputed funds are ring-fenced and cannot be released to the Vendor until the dispute is resolved. |
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5.4.13 Vendor Rights — What Escrow Means for the Vendor
While the escrow mechanism is primarily a buyer protection tool, it also provides important protections and rights for Vendors:
Transparent payout timeline: Vendors have full visibility into their pending payout status, reserve amounts, and expected release dates through the Vendor Dashboard. There are no hidden holds or unexplained deductions.
Defined maximum hold periods: AqNova's escrow holds are governed by defined timelines. The standard automatic release is 14 days from confirmed delivery. Dispute holds are resolved within 10–20 Business Days. Compliance holds have defined maximum durations (Section 5.4.7).
Right to participate in dispute resolution: Vendors have a full opportunity to submit evidence during BPP investigations and dispute resolution proceedings. AqNova cannot deduct from a Vendor's payout without completing the applicable BPP investigation process.
Reserve release schedule: reserve amounts are released according to the schedule published in the Vendor Dashboard. AqNova does not retain reserve amounts beyond the schedule unless a claim or investigation requires it.
Prompt payout on favorable BPP decision: if a BPP claim is not upheld, the dispute hold is released within 24 hours and the funds are included in the next payout cycle.
No surprise deductions: all deductions from Vendor payouts (commission, TCS/tax, reserve, BPP-funded refunds) are itemized in the settlement statement provided with each payout. Vendors can verify and contest any deduction within 30 days by contacting vendors@aqnova.co.
Arbitration rights: unresolved payout disputes between Vendors and AqNova are subject to the commercial arbitration process described in Section 5.3.9 of the Dispute Resolution Policy.
5.4.14 Escrow in Insolvency — What Happens if AqNova Ceases Operations
This section addresses the important question of what happens to Buyer and Vendor funds if AqNova (Arivon Holding Corporation) were to cease operations due to insolvency, liquidation, or other circumstances. This is an important disclosure that responsible marketplace operators provide to their users.
| Insolvency Disclosure — Buyer and Vendor Funds AQNOVA IS NOT A BANK. BUYER FUNDS AND VENDOR PENDING PAYOUTS ARE NOT HELD IN A SEPARATE CLIENT MONEY ACCOUNT PROTECTED BY DEPOSIT GUARANTEE SCHEMES (SUCH AS THE FDIC IN THE US, FSCS IN THE UK, OR EQUIVALENT). IN THE EVENT OF AQNOVA'S INSOLVENCY: BUYERS: — Funds for orders placed but not yet delivered are held within AqNova's payment processor accounts. The processor holds these funds in AqNova's merchant account — not in a segregated client money account. — If AqNova enters insolvency, buyer claims for undelivered orders would be treated as unsecured creditor claims against AqNova's estate, unless the applicable payment processor has specific fund safeguarding obligations under its own regulatory license. — Buyers are advised to use credit cards where possible, as credit card chargebacks under the FCBA (US) or equivalent consumer protection law provide a payment reversal right independent of AqNova's solvency. VENDORS: — Pending payouts are unsecured obligations of AqNova. In insolvency, Vendor pending payouts would rank as unsecured creditor claims. — AqNova maintains business continuity insurance and operational reserves to minimize the risk of sudden cessation of operations. PROCESSOR SAFEGUARDING (EU/UK): — EU Payment Institutions (Stripe Europe, Adyen) are required under PSD2 to safeguard relevant funds — amounts received from or for payment service users that have not been settled to payees by the end of the following business day. This obligation applies to the payment institution's own obligations, not necessarily to AqNova's merchant account balance. AQNOVA'S RISK MITIGATION: — AqNova maintains financial reserves and insurance coverage to support Platform continuity. — In the event of AqNova winding down operations, AqNova would make best efforts to fulfill pending orders or refund Buyers before ceasing operations. — Regulatory wind-down procedures would apply where required by applicable financial regulatory licensing. |
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5.4.15 Contact Information — Escrow & Payment Protection
| AqNova — Escrow & Payment Protection Contacts BUYERS — Escrow & Payment Queries: Escrow Status / Payment Hold: support@aqnova.co [Subject: Escrow — Order #] BPP Claim (dispute hold): My Orders > Open Dispute (self-service) BPP Support: buyers@aqnova.co Unauthorized Transaction: security@aqnova.co [URGENT] VENDORS — Payout & Reserve Queries: Payout Status: Vendor Dashboard > Payouts Payout Dispute: vendors@aqnova.co [Subject: Payout Dispute] Reserve Status: Vendor Dashboard > Payouts > Reserve Status Compliance Hold Inquiry: compliance@aqnova.co [CONFIDENTIAL] High-Value Payout Arrangements: vendors@aqnova.co [Subject: High-Value Payout] Settlement Statement Dispute: vendors@aqnova.co [Subject: Settlement Dispute] AML / COMPLIANCE: AML Compliance Officer: compliance@aqnova.co SAR-Related Holds (not disclosable): compliance@aqnova.co [CONFIDENTIAL] LEGAL / REGULATORY: Legal Notices & Formal Claims: legal@aqnova.com Regulatory Authority Inquiries: legal@aqnova.com PAYMENT PROCESSOR REGULATORY CONTACTS (for reference): Stripe (FCA registered): stripe.com/en-gb/privacy | FRN 900461 Adyen (DNB licensed EMI): adyen.com | DNB license no. R143110 PayPal (FCA): paypal.com/uk/webapps/mpp/ua/privacy-full RBI (India — payment aggregators): rbi.org.in BACEN (Brazil): bcb.gov.br Registered Office: Arivon Holding Corporation C/O Arivon Holding Corporation, 2571 Saturn Avenue, Unit #265 Huntington Park, CA 90255, USA California File Number: B20250418195 | EIN: 41-3210066 | D-U-N-S: 142957477 GB EORI: GB511467217000 Nigeria (Sahara Eagle Ltd) — Reg: 1957145 | Tax ID: 31052811-0001 | NEPC: 0030281 |
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AqNova Marketplace | Global Legal Footer Framework | Section 5.4: Escrow & Payment Protection Terms
© 2026 Arivon Holding Corporation. All rights reserved. Effective April 7, 2026. Version 1.0.