To fight global terrorism, money-laundering and fraud, banks and payment institutions have to follow strict regulations and laws set out by local and international governing bodies. Which means that, despite best efforts, there may be times when TransferMate, either direct or via a Partner may request further information about a Payee, or a Supplier, or may request invoice documentation to support a transaction or series of transactions.
Unfortunately, if a request for information happens, there’s often no information that a bank or payment institution can legally provide during the process. TransferMate appreciates that such situations can cause confusion and frustration, and on occasion slow down speed of payment delivery, as such we have compiled this FAQ for requests for information (RFI).
There is no single reason why a payment may be held by a bank or payment institution. However, there are common trigger points:
1. Payee / Supplier name is a close match to an individual/entity listed on the US Treasury’s Office of Foreign Assets Control (“OFAC”) Specially Designated Nationals (“SDN”) list, or similar list issued by another jurisdiction’s financial sanction agency
2. The bank or financial institution used by the Payee / Supplier is sanctioned by OFAC, or another jurisdiction’s financial sanction agency
3. The location of the Payee / Supplier, or their bank or financial institution, is considered prohibited in accordance with TransferMate’s risk appetite. Countries deemed prohibited are Cuba, Islamic Republic of Iran, Democratic People’s Republic of (North) Korea, Myanmar, the Republic of Niger, the Russian Federation, Syrian Arab Republic and Venezuela. Belarus is not prohibited however transactions with a nexus to Belarus are assessed on a case by case basis.
4. While payments to Ukraine are not prohibited, TransferMate conducts real-time risk assessment to ensure no nexus to Crimea Region of Ukraine, Donetsk People’s Republic (“DNR”), Luhansk People’s Republic (“LNR”), Kherson and Zaporizhzhia
5. The location of the Payee / Supplier, or their bank or financial institution, is considered higher risk (though not prohibited per-se) in accordance with TransferMate’s geographic risk scoring methodology. Jurisdictions that TransferMate considers to be high-risk are determined following the application of TransferMate’s geographic risk scoring methodology which includes consideration of industry best practice, external data sources (including the Financial Action Task Force’s (“FATF”) List of Jurisdictions Under Increased Monitoring and the EU Commission’s List of High Risk 3rd Countries) and internal assessment. However, not all payments are held for further information in-line with TransferMate’s real-time risk assessment. Please see table below for a listing of the high-risk countries
6. Potentially fraudulent red flags are present in the transaction. In some cases, this could simply be a high-value payment to a first-time Payee / Supplier, or the Payee bank has recorded a different name to the Payee name provided in the transaction record. In such cases, TransferMate may request a confirmation that the Payee bank details are correct to lower the risk of business email compromise (“BEC”)
7. Use of initials and titles in the beneficiary name can result in RFI in order to discount a potential match e.g. P. Ryan, Mr. Ryan
8. Abbreviations or acronyms in the Payment Details field can present a potential match for association with terrorist or militant groups
If a payment is held by TransferMate, or by one of its global banking partners, our Operations team will reach out to your Account Admin. To ensure successful delivery of funds, it is important that you promptly respond to any request for additional information to prevent further delays to your payment, or disruptions in future payments. Usually, 10 business days is permitted to respond however this could be less so please take note of the expected response date.
The nature of information requests depends on several factors including but not limited to who is requesting the information, for example TransferMate, its global banking partner, or the receiving financial institution, and the potential inherent risk scenario. Below shows some examples of what to expect for the most common triggering points:
- Complete (legal) name of the Payee / Supplier
- Meaning of abbreviations or acronyms in the Payment Details field
- Other personal identifiable information such as address or date of birth for a Payee that is a natural person
- Detailed reason for the payment, and / or a copy of the specific invoice pertaining to the payment
- Other detail on the Payee / Supplier, for example their website, or in rare cases, the names of the persons who have beneficial ownership of the Payee / supplier
It is increasingly common for cybercriminals to use a tactic called Business Email Compromise (“BEC”) to commit payments fraud. In this scheme, criminals may:
- Impersonate an employee or executive requesting that payments be made to an illegitimate vendor or bank account
- Impersonate an existing vendor via email to provide illegitimate bank account information for future payments
If you receive payment instructions from a supplier’s employee or an executive via email, or if you receive bank account number updates via some other means, be sure to follow up with them or a trusted contact by phone to verify their instructions. Never rely on email alone, as it may have been compromised. Other best practices include obtaining evidence of the new bank details provided, for example by requesting a bank statement from the Supplier.
Should you wish to know about other practical steps to help combat fraud, please contact our Customer Service team.
As a rule, if TransferMate does not receive a response within 10 calendar days, the payment may be cancelled, and the funds returned to you.
If the information request was triggered by a potential OFAC or similar financial sanction agency match, failure to provide information may result in the funds being held by TransferMate, or by our banking partner.
To minimize the possibility of your payments being held or delayed, the following is critical:
1. Do not send payments to sanctioned individuals, entities, or jurisdictions
2. If intending to send payments to higher risk countries, contact our Customer Service team for further advice so to reduce the risk of delayed payments
3. Always ensure that payee / supplier names are complete and accurate including full names and addresses. Always ensure that names of individuals include at least the full first name and surname, and for corporate suppliers, it is advised to enter the full legal name as stated on the invoice
If you have any questions on this process, please feel free to contact customerservice@transfermate.com
Payments to the below countries require further information to support the activity.
Jurisdiction
Afghanistan
Algeria
Barbados
Belarus
Benin
Bulgaria
Burkina Faso
Burundi
Cameroon
Central African Republic
Croatia
Democratic Republic of the Congo
Gibraltar
Guinea Bissau
Haiti
Iraq
Israel
Jamaica
Kenya
Laos
Lebanon
Libya
Mali
Monaco
Mozambique
Namibia
Nigeria
Palestine
Panama
Philippines
Senegal
Somalia incl Somaliland
South Africa
South Sudan
Sudan
Tanzania
Trinidad and Tobago
Uganda
Ukraine
United Arab Emirates
Vanuatu
Vietnam
Yemen
