Proposed process
Review before execution.
The intended process is designed around documented business activity, identifiable counterparties and a defensible payment purpose.
- 01
Business Questionnaire
A set of non-sensitive questions describing the company, ownership, activity and anticipated payment needs.
- 02
KYB Review
Review of corporate documents, directors, shareholders and UBOs; sanctions, PEP and adverse-media screening; and assessment of real activity and expected transactions.
- 03
Transaction Review
Review may include invoice, contract, payer and payee, goods documentation, source of funds and the economic rationale for the payment.
- 04
Service Execution
If a proposed service is later approved and passes the required compliance review, it may be carried out only after all required registrations and legal requirements are satisfied and the parties, instructions, agreements, funds flow, settlement, custody or possession and control, reporting duties and access to records are documented. No provider, execution partner or delivery model is currently approved. Availability and timing cannot be guaranteed.
Any future transaction will be subject to the controls applicable to the approved operating model and may be delayed or declined where required information or legal authority is insufficient.