3rd Party Payments

Addressed by:
  • Approval to Make 3rd Party Payment: Compliance approval is required for 3rd party payment and monitoring.
  • Bank to Bank Transfers (Low Risk Jurisdictions): Payment can only be made via bank-to-bank transfers from countries with strong AML controls (typically low-risk jurisdictions).
  • Book Entry or DVP: The product is not easily transferable, and payment flows are restricted due to book entry (recorded electronically) and Delivery vs. Payment (DVP), a settlement system that stipulates cash payment must be made prior to or simultaneously with the delivery of the security to a specified party.
  • Know Your Business (KYB): Includes taking steps to gain an understanding of a customer's business activities, including the nature of the business to be taken with a bank and the anticipated volume and value of the business.
  • Limits on 3rd Party Payments: Restricted capacity to make 3rd party payments.
  • Payment Terms Defined in Agreement or Contract: A product or service requires entering into a legally binding agreement or contract between specified parties that outlines the drawdown and repayment terms.
  • Restricted to Regulated Firm: Restrictions on the types of customers (regulated Financial Institutions) to whom the product can be offered.
  • Source of Wealth (SOW): The Source of Wealth (SOW) of the client is understood.
  • SWIFT Confirmation: Requires confirmation via SWIFT that payment will be used solely for agreed purposes pre-release and post-payment
  • Transactional Due Diligence (TDD): Conducts a detailed examination of specific transactions identified as being higher risk.
  • Transparent Flow of Funds: Maintains a transparent flow of funds.