🏦 Escrow Custodian Services for UAE Banks
A proposal and integration-readiness pack for a licensed escrow arrangement — prepared for ADCB, Mashreq, Emirates NBD and other UAE custodians.
1Overview
CGT rents heavy equipment with certified operators and manages third-party owners' idle machines in Abu Dhabi, operated through the FleetOps platform. To protect clients and equipment owners, CGT wants to hold project funds in a bank-licensed escrow and release them against verified, client-approved milestones.
- Licensed (CN-6070681), VAT-registered (TRN 104137691300003), insured; NEBOSH-certified operators.
- FleetOps digital audit trail: GPS, photo evidence, client-approved timesheets on every billable day.
- A software escrow engine with a tamper-evident, externally time-anchored ledger.
- Reduced dispute risk — releases are client-approved and evidence-backed.
- Automated, itemised reconciliation against your statements via a defined API.
- Clear custody boundary: the bank holds funds; CGT only instructs and audits.
Operational flow (per project)
- Per-project sub-accounts / virtual IBANs — each independently balanced and reconcilable.
- Milestone-based releases — only on a client-approved instruction from CGT.
- Multi-party splits — owner net, CGT fee, maintenance, VAT (5%) in one instruction.
- Retention — default 10% held for a 14-day defect window, then released absent a dispute.
- Dispute freeze — a filed dispute freezes the account until resolved; no releases meanwhile.
- Immutable ledger — every movement is hash-chained and externally time-anchored; VAT TRN 104137691300003 shown on statements.
2UAE Bank Escrow Requirements — Compliance Matrix
Honest status against typical UAE bank escrow requirements.
| Bank requirement | CGT solution | Status | Supporting doc |
|---|---|---|---|
| Per-project sub-accounts / virtual IBANs | Software models each project as an independent escrow account with its own balance & statement. | Bank alignment | Technical Integration |
| Multi-party payouts | Single release instruction splits owner / CGT fee / maintenance / VAT. | Built | API Specification |
| Conditional / milestone release | Guarded state machine; release only on client-approved instruction. | Built | Workflows |
| Immutable audit trail | Hash-chained ledger, externally time-anchored; reconciled to bank statements. | Built | Overview |
| API / webhook support | REST interface (deposit/release/refund/balance) + settlement webhooks; SFTP/CSV fallback. | In progress | Technical Integration |
| KYC / AML for all parties | CGT KYC docs available; client/owner KYC + third-party AML screening being implemented. | In progress | KYC / AML |
| UAE data residency | Planned UAE-region hosting; access limited to authorised staff, full access logs. | In progress | KYC / AML |
| Dispute resolution | Client agreements name Abu Dhabi Commercial Conciliation & Arbitration Centre (ADCCAC). | Bank alignment | Risk & Insurance |
| Escrow fund protection / insurance | Segregated escrow; bank guarantee or insurance to be arranged per your requirement. | Bank alignment | Risk & Insurance |
Contact CGT
3FleetOps Escrow API — Technical Integration
FleetOps integrates through a thin adapter mapping to the bank's API. Each call carries a CGT reference and an idempotency key; the bank's providerRef is stored against every movement for reconciliation. Final endpoints/fields conform to the bank's specification.
| Operation | Method · path | Purpose |
|---|---|---|
| openAccount | POST /escrow/accounts | Open/link a project sub-account → providerRef |
| deposit | POST /escrow/deposit | Collect/allocate client funds to a sub-account |
| release | POST /escrow/release | Payout to CGT/owner (supports split beneficiaries) |
| refund | POST /escrow/refund | Return held funds to the client |
| getBalance | GET /escrow/accounts/:ref/balance | Held balance for reconciliation |
| events | Webhook | Deposit cleared / payout settled callbacks |
Sample — deposit (cURL)
curl -X POST https://bank.example/api/escrow/deposit \
-H "Authorization: Bearer $BANK_TOKEN" \
-H "Idempotency-Key: cgt-dep-001" \
-H "Content-Type: application/json" \
-d '{
"accountRef": "ESC-2026-0007",
"amount": 50000,
"currency": "AED",
"clientId": "CL-AD-12345"
}'
Sample — response
{
"providerRef": "BANK-ESC-98765",
"status": "settled",
"settledAt": "2026-08-14T10:00:00Z"
}
Webhook handler (Node.js)
// POST from bank on settlement
export async function POST(req) {
const evt = await req.json(); // { providerRef, accountRef, type, amount, settledAt }
verifyHmac(req.headers, evt); // shared-secret signature
await recordEscrowEvent(evt); // reconcile against our ledger by providerRef
return new Response("ok");
}
Sandbox: request credentials at bank-integration@cgt.llc. Fallback: if the API is unavailable, transactions are exchanged via SFTP (CSV) within 24 hours.
4KYC / AML & Compliance
- Trade Licence CN-6070681, VAT TRN 104137691300003, ownership structure and authorised signatories provided at onboarding.
- Trade licence, VAT TRN, authorised-signatory ID (and passport/UAE ID for individuals).
- Trade licence (if a business), Emirates ID, bank account details for payouts.
Screening & reporting (being implemented): a third-party AML/sanctions screening provider (to be onboarded) against UN/US/EU lists; suspicious-transaction handling per UAE regulation. CGT will align its process to the bank's own AML program and thresholds.
Data protection: UAE-region cloud hosting (to be finalised); encryption at rest; full access logs on every escrow action (who approved what, when).
5Risk Mitigation & Insurance
| Risk | Mitigation | Responsible |
|---|---|---|
| Misrouted payment | Client-approved instruction + bank verification before any release. | CGT + Bank |
| Fraudulent transaction | AML screening + immutable, anchored ledger; dual reference (CGT ref + providerRef). | CGT + Bank |
| Bank insolvency | Escrow funds segregated from the bank's own assets (per the bank's escrow terms). | Bank |
| Defect after completion | 10% retention held for a 14-day window before final release. | CGT |
Fund protection: escrow balances segregated; a bank guarantee or an insurance policy over escrow balances to be arranged if the bank requires it (option to be agreed).
Dispute handling: a client/owner files a dispute in FleetOps → the account is frozen (no releases) → resolution via ADCCAC or the bank's process, targeted within 30 days or the bank's SLA.
Liability boundary: CGT issues client-approved instructions and does not hold funds; the bank is custodian and releases only on those instructions.
6Escrow Workflow Diagrams
Deposit → release
Weekly timesheet approval
Dispute & freeze
7Contact & next steps
Curve General Transport L.L.C. · Abu Dhabi, UAE · Trade Licence CN-6070681 · VAT TRN 104137691300003
Name & signature: ____________________