Guidance on Currencycloud’s Transaction Monitoring processes

What do our systems screen/monitor?

All transactions into and out of the Currencycloud ecosystem for all entities are automatically screened in real-time against various controls and checks. 

All transactions into and out of the Currencycloud ecosystem for all entities (companies and individuals) are automatically monitored against various controls and checks. 

When does this take place?

This screening happens before an inbound fund (receipt or collection) is credited to the client account or before an outbound payment is submitted to the banking network.

This monitoring happens post-transaction: after inbound funds have credited the client account or outbound payments have been submitted to the banking network.

What can the outcome be?

Transactions can either:

1. Pass screening automatically.
2. Fail screening and generate an alert for manual review.
3. Be rejected automatically - without manual review.  

Alerts are manually reviewed by a Compliance Specialist. Transactions are then ultimately either manually approved, manually rejected, or held for further review.

The activity of some entities may create an alert. This means the transactional behaviour of an entity needs to be investigated by a Compliance Specialist. Alerts are reviewed and in some cases we may subject the entity to enhanced due diligence or even off-board the entity.

How do we review transactions that have alerted for manual review?

Where possible we aim to resolve alerts internally - using our knowledge of the entity in question, their previous transactions, the expected behaviour of other clients in that segment, and any KYC information or documents we already have on file. 

However it’s important to note that sometimes Currencycloud only has visibility of a certain part of an entity’s activity. As our client (either regulated or unregulated), you may have more information from your relationship with the entity. 

So in some cases the real-time/retrospective team will need to request further information to resolve an alert. Clear and comprehensive information in response to our request always helps our teams resolve alerts as quickly as possible.

If there’s any other information you’d like to provide in addition to what we request, please do share this with us - making it clear what the information is and how it supports your answer to the query. 

What are the main questions Currencycloud 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

How can I provide documents before I submit a transaction (e.g. high-value transactions)?

Documents can be sent to kycrequests@currencycloud.com. When sending the documents, please make it clear who the transaction relates to (e.g. account IDs, transaction IDs).

Specific guidance on how to manage large transactions can be found in the Help Centre article here.

If I proactively provide documents in advance, does that mean I won’t receive any further requests for information on that transaction?

No. Sending documents in advance doesn’t guarantee that we won’t need to request further information at a later stage.

Proactively sending documents simply means that we skip a step in the transaction review journey because you don’t have to wait for the initial request for information from us.

If a transaction has alerted for manual review it will be reviewed in light of previous transactional behaviour, any information we have on file, and any documents you might have provided in advance. 

But if further information is required, this will be requested.

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)