In order to combat global terrorism, money laundering, and fraud, banks and payment institutions are required to adhere to strict regulations and laws established by local and international governing bodies. Consequently, there may be instances where Apus needs to request additional information regarding a Payee or a Supplier, including invoice documentation, purchase agreements, or commercial contracts, to support a transaction or series of transactions. Unfortunately, during this process, banks and payment institutions often have legal constraints that prevent them from providing any information.
We understand that such situations can lead to confusion and frustration, and occasionally result in delays in payment delivery. To assist our customers in these circumstances, we have compiled this Requests for Information (RFI) reference.
Why is my payment on hold or why am I being asked for further information?
There are various reasons why a payment may be held by our banking partners or us. However, there are common triggers, including:
- The name of the Payee or Supplier closely matches an individual or entity listed on the US Treasury’s Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) list or a similar list issued by another jurisdiction’s financial sanction agency.
- The bank or financial institution used by the Payee or Supplier is sanctioned by OFAC or another jurisdiction’s financial sanction agency.
- Apus conducts real-time risk assessments to ensure there is no connection to the Crimea Region of Ukraine, Donetsk People’s Republic (DNR), Luhansk People’s Republic (LNR), Kherson, and Zaporizhzhia.
- The location of the Payee or Supplier, or their bank or financial institution, is considered higher risk (though not explicitly prohibited) according to Apus’s geographic risk scoring methodology. The determination of high-risk jurisdictions by Apus is based on industry best practices, external data sources (including the Financial Action Task Force’s List of Jurisdictions Under Increased Monitoring and the EU Commission’s List of High-Risk 3rd Countries), and internal assessments. However, not all payments require further information based on Apus’s real-time risk assessment. Please refer to the table below for a list of high-risk countries.
- Potential fraudulent indicators are detected in the transaction. This could be a high-value payment to a first-time Payee or Supplier or a discrepancy between the Payee name provided in the transaction record and the name recorded by the Payee bank. In such cases, Apus may request confirmation of the correct Payee bank details to mitigate the risk of business email compromise (BEC).
- The use of initials, titles, abbreviations, or acronyms in the beneficiary’s name can trigger an RFI to rule out potential matches with associated terrorist or militant groups.
How can I ensure the release of my payment?
If Apus or one of its global banking partners places a payment on hold, our Operations team will contact your Account Admin. To ensure timely delivery of funds, it is crucial that you promptly respond to any requests for additional information to prevent further delays or disruptions in payment processing. Typically, a response time of 10 business days is permitted, although it may be shorter in certain cases. Please take note of the expected response date.
What type of information may be requested?
The nature of information requests depends on various factors, including the entity requesting the information (Apus, global banking partner, or receiving financial institution) and the inherent risk scenario. Here are some examples of commonly requested information for different triggering points:
- Complete (legal) name of the Payee or Supplier
- Clarification of abbreviations or acronyms used in the Payment Details field
- Other personally identifiable information such as address or date of birth for natural person Payees
- Detailed explanation for the payment or a copy of the specific invoice related to the payment
- Additional details about the Payee or Supplier, such as their website, or in rare cases, the names of individuals with beneficial ownership of the Payee or Supplier
Why am I asked to verbally confirm Payee bank information or validate it through another means?
Verifying Payee bank information verbally or through alternative methods is becoming increasingly necessary due to the rise of cybercriminals employing Business Email Compromise (BEC) tactics to commit payments fraud. In this scheme, criminals may:
- Impersonate an employee or executive, requesting payments to be made to an illegitimate vendor or bank account.
- Pose as an existing vendor via email to provide fraudulent bank account information for future payments.
If you receive payment instructions from an employee or executive of a supplier via email or receive updates to bank account numbers through other means, it is essential to follow up with them or a trusted contact by phone to verify the instructions. Relying solely on email communication is not advisable, as it may have been compromised. Other best practices include obtaining evidence, such as a bank statement from the Supplier, to validate any new bank details provided.
If you require additional guidance on preventing fraud, please reach out to our Customer Service team.
What happens if I don’t respond to the request for further information?
As a general rule, if Apus does not receive a response within 10 calendar days, the payment may be canceled, and the funds returned to you.
If the information request was triggered by a potential match with OFAC or a similar financial sanction agency, the failure to provide the requested information may result in the funds being held by Apus or our banking partner.
How can I prevent my payments from being held?
To minimize the likelihood of your payments being held or delayed, it is crucial to take the following measures:
- Avoid sending payments to individuals, entities, or jurisdictions subject to sanctions.
- If you intend to send payments to higher risk countries, contact our Customer Service team for guidance to reduce the risk of delays.
- Always ensure that the names and addresses of payees or suppliers are complete and accurate. For individuals, include at least their full first name and surname, while corporate suppliers should be identified by their full legal name as stated on the invoice.
We currently cannot send payments to or receive payments from the following jurisdictions (as of July 2023)
- Afghanistan
- Albania
- Barbados
- Belarus
- Burkina Faso
- Cambodia
- Cameroon
- Cayman Islands
- Central African Republic
- Cuba
- Croatia
- Democratic Republic of the Congo
- Democratic People’s Republic of (North) Korea
- Gibraltar
- Guinea
- Guinea Bissau
- Haiti
- Iraq
- Islamic Republic of Iran
- Jamaica
- Jordan
- Kenya
- Laos
- Libya
- Mali
- Morocco
- Mozambique
- Myanmar
- Nicaragua
- Nigeria
- Pakistan
- Panama
- Senegal
- Somalia
- South Sudan
- Syrian Arab Republic
- Tanzania
- The Russian Federation
- Trinidad and Tobago
- Uganda
- Ukraine
- Vanuatu
- Venezuela
- Yemen
- Zimbabwe
