TransferWise is on a mission. Our journey brings us into contact with all sorts of customers. Most of our customers (like you) are the good guys, but sometimes we come across bad guys trying to misuse TransferWise. TransferWise has a dedicated compliance team. Part of their job is to ensure that TransferWise is safe, and not just safe for you as a customer, but for other people who might fall victim to some form of financial crime. It is not just a regulatory obligation for us – we truly believe in disrupting and deterring criminals and ensuring that we do not give them the opportunity to use TransferWise.
In order for us to ensure we are not facilitating financial crime, a lot of things happen in the background. Some are trade secrets and cannot be shared, but this article should help you understand why an account might be blocked, frozen or closed, what you can do about it, and why your money will always be safe.
One of our regulatory obligations is to understand the flow of funds by understanding the purpose of the account and how the account is being used. To do this we carry out various checks. Sometimes, the good guys get caught up in these checks. There are various reasons for this. For example, in our last blog, we told you about all the innovative stuff that we do in compliance, such as machine learning. The machine learns from patterns that we have previously identified as suspicious. This means that sometimes a good customer’s transactional behaviour appears similar to a pattern that we have previously identified as suspicious, but may instead be completely legitimate. However, we won’t know for sure until we have checked. This might mean an account is temporarily suspended while these checks are underway.
Where we cannot determine that the money has been legitimately obtained from the information we hold on file about a customer, or where we have reason to believe or have information that an account may be involved in some form of deceit, or crime, we need to take the time to investigate. This means that we may, at times, temporarily suspend accounts to allow for the investigation to be concluded. During this time, a customer may be unable to get to their money but the money remains in the account and is held safely. We completely understand that this can be a really frustrating experience, but rest assured we work as quickly as possible to minimise the impact on our good customers.
Normally, the good customers do not wait long to have their accounts unfrozen, as there is usually nothing suspicious about them and checks can prove this quite easily. We will always do our very best to contact the customer in every case where there is an issue with an account. Sometimes, this is not possible. The law requires us to keep information about on-going investigation to ourselves, where there is a risk that sharing that information would prejudice an ongoing investigation or the outcome of such an investigation. This means that we may not be able to say how long an account will remain suspended or why funds are frozen.
While our primary objective is to keep the bad guys out, we also have an Acceptable Use Policy (AUP). This policy relates not just to financial crime but also to other aspects of TransferWise’s risk tolerance. Some of the activities listed there may pose certain risks, such as reputational risk to Transferwise, and therefore we may be unable to offer our services to persons engaged in those activities. In instances where the activity on the account falls within our AUP, we may close an account or temporarily suspend it while we seek clarification from the customer.
If you are one of the good customers who has had their account suspended, or funds frozen, we have most likely already got in touch. In the first instance, we try to find out more by using the information we hold about a customer or open source searches. If we are still unable to follow the money, determine account activity or purpose of transactions, we will get in touch with the customer. You can help us by responding to our correspondence. We may ask you to explain your account activity or provide documentation as evidence. The quicker you are able to respond, the quicker the issue will get resolved.
If you are one of the bad guys, please help us by going away and re-thinking your life choices.
Of course it wasn’t. But we rarely make mistakes when investigating financial crime. Should a customer be one of the good guys who finds themselves in a (very rare) situation where their account is closed, and you think this decision has been taken in error, we have an appeal process. Let us know why, in your opinion, you think we made the wrong call.
Your money is safe. While we carry out our investigations, your money remains safe and is safeguarded along with all other customer money. Once our investigations are complete, you will have access to the money in your account unless there is a legal reason that we cannot give it back, such as: it does not belong to you, or it has been subject to a confiscation or freeze order from law enforcement agencies. When either of these happens, the law enforcement agency responsible will get in touch with you.
We believe we are building safe products and we want to ensure that they remain safe. We are committed to disrupting financial crime and ensuring our products are only used for the intended purpose and that we do not, even unknowingly, facilitate financial crime or facilitate the flow of proceeds of crime. We understand that some of our good customers may get caught up in our fight to keep TransferWise safe and that they may suffer some inconvenience as a result, but be assured there is a dedicated team trying to make sure we do this in the least disruptive way possible, if at all. We continue to grow our compliance team and to also fine tune our innovative and super secret tools and processes to ensure we continue to keep the bad guys out.
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