Payment to Designated Person or Firm or Country

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).
  • Early Termination Clause: Legally binding agreements relevant to the service include an early termination clause for high-risk clients or sanctions breaches.
  • Event Triggered Payment: Holds no investment value and pays out only upon the occurrence of a specific, verifiable event as determined by the product provider.
  • Event Triggered Review: Ongoing monitoring of a business relationship that is triggered by a specific event and includes a view of customer information, risk profile and transactions. Events can include adverse news, a change in status, a change in address, a request for a higher-risk product or service, a change in beneficial ownership or control, a type of business, a move to a higher-risk country, or unusual activity.
  • 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.
  • Low Risk Multi-Banked Customer: The customer must establish more than one relationship with a firm or another official body (e.g., a regulator) in a low-risk jurisdiction.
  • No Transactions Prior to CDD or EDD: Entering into a transaction before completing CDD (Customer Due Diligence) or EDD (Enhanced Due Diligence), as appropriate, is not allowed.
  • On-Going Screening: Daily sanctions and adverse press screening, in addition to the risk review cycle.
  • Originator and Beneficiary Information: Require that originator and beneficiary information be included in the payment.
  • Restricted to Regulated Firm: Restrictions on the types of customers (regulated Financial Institutions) to whom the product can be offered.
  • Sanctions Payment Filtering: Screens financial transactions to identify potential matches against international economic and financial sanctions.
  • SWIFT Confirmation: Requires confirmation via SWIFT that payment will be used solely for agreed purposes pre-release and post-payment
  • Traded on Regulated Exchange: Traded on a regulated exchange in a low-risk jurisdiction.
  • Transactional Due Diligence (TDD): Conducts a detailed examination of specific transactions identified as being higher risk.