The application was going fine and then a message arrives asking for the source of funds, an organisational chart and six months of statements. Nothing has gone wrong. What has happened is that the file moved into an AML check, and that review has its own logic — one that is easier to work with once you can see it.
This is not a glossary. What the checks are called and what they establish is set out in our piece on KYC and KYB. This is about the review itself: what starts it, what the questions actually mean, and what makes it short.
Contents
- Why you are asked at all
- What triggers extra questions
- What «source of funds» actually means
- If funds are held during a review
- How to make the review short
- After approval it does not stop
- What to keep ready
- In short
Why you are asked at all
A payment provider is legally obliged to know who its merchant is, what it sells, where the money comes from and whether the pattern of payments matches that description. It is not discretion and it is not suspicion: a provider that skipped it would lose its own permissions. That is why «we would rather not share that» has no version that works — the alternative to answering is not a faster approval, it is no account.
The practical consequence is worth stating plainly. The reviewer is not looking for a reason to refuse. They are looking for a consistent story, and your job is to make the story easy to verify.
What triggers extra questions
- A mismatch between description and site. The single most common trigger, and entirely in your control.
- Turnover that does not match the business. A young company forecasting large volume is not refused for it — it is asked where the volume comes from.
- A complicated ownership chain. Layers of holding companies are normal; unexplained layers are not.
- Sudden change after approval. New countries in the flow, a jump in average ticket, a new product line nobody was told about.
- Counterparties that cannot be identified. Payments to or from entities with no visible business is the classic reason for a second round.
Which of these weighs most depends on the category the business falls into, explained in our piece on what high-risk, middle-risk and low-risk payments are.
What «source of funds» actually means
Two different questions get asked with similar words, and answering the wrong one costs a round of correspondence.
Source of funds is about a specific amount: where did this particular money come from. Answered with statements, a contract, an invoice, a sale agreement — a document tying the amount to an event.
Source of wealth is about the person: how the beneficial owner came to have money at all. Answered with a history — a business sold, years of salary, a dividend record — and only asked when the amounts justify it.
For a trading company the first is usually enough, and the answer is mostly already in your accounting. Assemble it as one document rather than a thread of forwarded emails.
If funds are held during a review
It happens, usually after a pattern change rather than at onboarding. Ask in writing what is being reviewed and what would resolve it, keep every answer in one thread, and do not start moving the remaining balance out in pieces — that pattern turns a routine question into a serious one.
Note also that a hold and a reserve are different things: the rolling reserve is 10% for 180 days, part of ordinary terms and released on schedule, while a review hold is temporary and specific. The published lines are on the pricing page.
The settlement mechanics are described under payment processing.
How to make the review short
Send the complete package once. Documents arriving in pieces over three weeks do not merely delay the review — each new item restarts the reading of it.
Answer the question asked. If the request is for six months of statements, six months of statements is the answer. A summary spreadsheet instead of the statements produces another request, not a faster decision.
Name the numbers before you are asked. Expected turnover, average ticket, countries of your customers, share of recurring payments. Volunteered figures get verified; withheld ones get investigated. The full document list is in our merchant approval checklist.
Explain anything unusual before it is found. A dormant year, a change of director, a previous closure. Context supplied by you is information; the same fact discovered later is a discrepancy.
Give the reviewer one contact who can decide. Reviews stall in inboxes far more often than in policies.
After approval it does not stop
Monitoring continues for the life of the account, which is why keeping the picture current is cheaper than explaining it later. Tell the provider before you add a country, a product line or a new payment model — an announced change is planning, an unannounced one is an anomaly. Where the money settles is described under business IBAN.
What to keep ready
A folder that stays current turns most future requests into a five-minute reply: the incorporation documents and the current register extract, the ownership chain drawn to a person, identity and address documents for the beneficial owners, the last six months of statements, two or three signed contracts, and a one-page description of the business as it actually operates today. Refresh it when something changes rather than when it is asked for.
In short
An AML review is a verification of consistency, not a test of trust. It asks who owns the company, what it sells, where the money comes from and whether the flow matches the description. Answer in one complete package, distinguish source of funds from source of wealth, volunteer the numbers, and flag anything unusual first. Do that and the review on a merchant account is a step in the process rather than the end of it.