⚖️ Legal notice
This checklist is intended solely for general information purposes and does not constitute legal, tax or compliance advice. Although the content has been carefully compiled on the basis of current laws and regulations, no rights may be derived from it. Always consult a qualified adviser for your specific situation.
Unsure about a payment?
Identification of the payer
Structural analysis
Risk assessment
👉 Request a KYC report →
Bank-grade KYC report · Within 48 hours · Professional & independent
STEP 1 · Check the payer
Does the name of the payer match the name of your client?
In which country is the payer based — and does that country fit the transaction?
Does the company have a website, visible activities and an identifiable UBO?
Is the payer on no sanctions list (EU, OFAC, UK HMT)?
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No online presence or identifiable owner = elevated risk. Always conduct a basic check.
STEP 2 · Understand the relationship
Why is this party paying on behalf of your client? Is there a business reason?
Is there a demonstrable relationship (parent company, group structure, agency agreement)?
Can you substantiate this relationship with documentation (contract, statement)?
Was the relationship established recently — only after sanctions came into force?
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No clear business explanation for the third-party payment = do not accept the payment.
STEP 3 · Analyse the payment
Is the amount logical in relation to the transaction (including VAT and costs)?
Are there conspicuously round amounts without a clear explanation?
Has the payment been split into multiple smaller amounts (structuring / smurfing)?
Is a single invoice being paid by multiple separate parties?
Does the payment come from a bank account in the name of the third party itself, or is an intermediary or payment service (such as an MSB or payment processor) being used?
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Deviations in amount or splitting = signal of possible fraud or deliberate concealment.
STEP 4 · Check the origin
Does the payment come from a different country than your client — and is that logical?
Is the country of origin on the EU list of high-risk third countries?
Is there a "detour": money from country A, via B, while goods go to C?
Does the payment run through a Free Trade Zone or a letterbox entity?
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Illogical payment routes = possible money laundering, sanctions evasion or VAT fraud.
STEP 5 · Apply common sense
Do you yourself understand how the payment logically fits together?
Can you explain the complete payment chain to your bank or accountant?
Have you not received time pressure to accept quickly without asking questions?
Is your overall feeling about this transaction positive — without any doubt?
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Doubt = stop and investigate further. Your instinct is a compliance instrument.
🚩 STOP IMMEDIATELY — do NOT accept the payment if:
- ⛔There is no clear explanation why this party is paying on behalf of your client.
- ⛔The payer cannot be verified: no company registration, no website, no UBO.
- ⛔The structure or route of the payment feels unnatural or excessively complex.
- ⛔You are experiencing time pressure to accept quickly without asking questions.
- ⛔The payment comes from a sanctioned country or a country on the EU high-risk list.
Unsure about a payment?
Identification of the payer
Structural analysis
Risk assessment
👉 Request a KYC report →
Bank-grade KYC report · Within 48 hours · Professional & independent