Escrow-document redaction is the removal of PII from holding agreements and wire instructions. The agent behind the account runs customer due diligence under MLR 2017 reg. 28 and must keep those records for five years under reg. 40, so identity data cannot simply disappear. anonym.plus cleans the circulated copy on your own device.
When this applies
These papers name the parties, the agent, and the bank with wire details. A reviewer needs the release terms, not the account numbers — and account numbers in circulation are exactly what payment-diversion fraud hunts for.
How anonym.plus handles it
- Load the papers into anonym.plus on your device.
- It flags party names, agents, and bank numbers.
- Release terms, amounts, and triggers stay in place.
- Swap or black out the confirmed PII.
- Save the clean document on your device.
What you need to provide
- The papers (DOCX, PDF, or scan).
- An operator; Replace keeps the clauses readable.
- Optional role map for party and agent labels.
PII entity types detected
| Category | anonym.plus entity type | Example |
|---|---|---|
| Names | PERSON | the signatory → [PARTY] |
| Org | ORGANIZATION | holding agent → [AGENT] |
| Finance | IBAN_CODE | holding account → [ACCOUNT] |
| Identifiers | NATIONAL_ID | VAT ref → [ID] |
| Contact | EMAIL_ADDRESS | agent email → [EMAIL] |
| Dates | DATE_TIME | release 31 Dec → [DATE] |
Compliance achieved
- Cleans the circulated copy while MLR 2017 reg. 28 due-diligence records stay whole.
- Respects the five-year retention duty in MLR 2017 reg. 40.
- Backs the security measures UK GDPR Art. 32(1)(a) expects, with AES-256-GCM at rest.
- Keeps release terms, amounts, and triggers whole for review.
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Limitations & cautions
You cannot redact the identity records the agent must keep: MLR 2017 reg. 28 requires the checks and reg. 40 keeps the evidence for five years, which sits against the storage-limitation instinct in UK GDPR Art. 5(1)(e). Bank numbers also hide in headers and wire blocks, so check those by hand.
Frequently asked questions
Do the release conditions stay?
Yes. The amounts, triggers, and timelines stay. Only personal and banking data changes.
Can the agent delete the identity data after completion?
Generally no. MLR 2017 reg. 40 requires customer due diligence records to be kept for five years after the business relationship ends. Redaction applies to the copies you circulate, not to that regulated record.
Can I process a scanned agreement?
Yes. Local OCR reads scanned pages, so IDs in image files are caught.