What are the main questions UQPAY needs to get comfortable with when reviewing a transaction that's alerted for manual review?
●Who is the sender?
●Where does the sender derive their funds from? Where relevant, who are their customers?
●Who is the recipient?
●What is the relationship between the sender and the recipient?
●What is the purpose of the transaction? Is that purpose legitimate given the relationship between the sender and recipient?
●Is the transaction in line with the sender/recipient's transactional history and profile?
What are the main types of information and documentation I could be asked to provide?
●Proof of identity: e.g. passport, driving licence, ID card
●Proof of address: e.g. utility bill, bank statement, mortgage statement
●Company registration documents: e.g. registered name, trading name, address
●Proof of business: e.g. sales invoices, product list/brochure, proof of shipping documentation (i.e. bill of lading, airway bill), business contracts/agreements
●Other information on the relationship between the sender and the recipient (e.g. how it was formed)
●Director/shareholder register (signed, dated, on headed paper) and employment history of those directors/shareholders
●Source of funds: e.g bank statement, payslips, audited business financials, loan contracts
●Source of wealth: e.g. Will, Grant of Probate, share sale certificates, asset and income declarations, dividend statements
●Property purchase/sale agreements (incl. price, location, agent/solicitor details etc.)
●Links to sender/recipient online presence (if not easily found from our own searches): e.g. LinkedIn profile, listing on ecommerce platforms
Do some transactions get escalated?
Yes. Depending on the risk profile of a transaction it may be escalated to more senior members of our Compliance function.
Our real-time screening team makes every effort to do as thorough a review as possible before escalating. But each transaction is judged on its own merits and the individual reviewing the escalation may ask that the real-time team request further information from you so they can make a decision on the transaction.
What types of transactions or entities are likely to receive greater scrutiny - and may result in requests for further information?
●Transactions from/to countries that pose a higher potential risk of financial crime
●Transactions from/to senders/recipients with minimal public web presence
●Large transaction values or companies processing large transaction values where no physical goods are shipped (e.g. marketing, consultancy) will likely be asked for director/shareholder information
●See our Help Centre article here for more information on non-permitted activity
If a transaction is manually rejected, can you tell me why?
This can be a sensitive area and there is a limit to how much information we can share.
We are able to share that the transaction has been rejected because:
●The sender/recipient are operating in a non-permitted activity
●The sender/recipient are trying to send money from a non-permitted jurisdiction
●You have not provided sufficient information for us to understand the transaction
If you're a regulated client then, on a case-by-case basis, we may share more information with you on the specific concerns we have - so that you can take appropriate action.
How can I provide a good response to a request for further information?
●In general, documents should not be older than 3 months
●PDF files only
●We do not accept Word, Excel etc. documents or screenshots (e.g. of bank statements, email chains, WhatsApp conversations)
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