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Quick Answer
An account review pauses outbound payments while your bank or payment provider verifies ownership, source of funds, and the nature of your business. Goods keep moving if you plan ahead: rank payments by consequence, keep a second verified account that can send on conventional rails, tell every supplier in writing what has changed, and release balances against documents rather than promises. Most reviews close once the document pack is complete, so build both the supplier plan and the compliance file before a review starts, not during one.
What an Account Review Actually Means
A review is not the same thing as a closure. During a review, the institution is completing customer due diligence on an existing relationship, and under the UK Money Laundering Regulations a firm can pause transactions while it does so, as set out in the FCA guidance on financial crime controls. Your money has not disappeared. It has been held at the point where the institution needs to confirm that it understands the payment.
In practice, three things change on the day a review begins. Outbound international payments stop or slow down, incoming credits may still post, and the relationship moves from a self service app to a named reviewer who has a checklist you cannot see.
The mistake most businesses make is treating the pause as a banking problem to argue about. It is a documentation problem to solve, and the businesses that solve it fastest are the ones that can produce documents the same day they are requested.
What the Bank Is Checking During a Review
Reviewers are not reading your whole business history. They are answering a short list of questions.
- Who owns and controls the company. Registry records, shareholder structure, and the identity of anyone with significant control.
- Where the money comes from. Contracts, invoices, and the trading history that supports the credits on the account.
- Whether the payment matches the profile. A business that has sent five payments a month for two years, then sends a payment ten times larger to a new beneficiary in a new country, will be asked about it.
- Who the counterparty is. Supplier name, address, and the goods being paid for.
- Which countries are involved. Sanctions screening runs on every party, including intermediate banks.
None of this is personal. It is a standard control that every regulated institution runs, and the same questions appear whether you bank with a large commercial bank or a smaller payment provider.
Why the Pause Lasts Longer Than the Deadline You Were Given
A review usually runs in rounds rather than one pass. The reviewer asks for a document, you send it, and the next question only appears after the first answer is accepted. Each round adds days.
Three things stretch a review:
- Partial answers. Sending one invoice when the reviewer asked for the contract, the invoice, and the shipping document means a new round starts.
- Unreadable or uncertified files. Screenshots, phone photos of paper, and unlabelled statements usually get sent back.
- Third party explanations. An answer that says "my agent handled it" without documents creates another question instead of closing one.
If you treat the first request as the only request and send a complete file, you remove most of the delay. That single habit is worth more than any escalation.
Which Payments Stop First
Not every payment behaves the same way during a review.
| Payment type | Typical behaviour during a review |
|---|---|
| Domestic transfer to an existing payee | Often continues, subject to limits |
| New international beneficiary | Usually held for review |
| High value outbound transfer | Held, with document request |
| Recurring payment already on file | Sometimes continues, sometimes paused |
| Card payment on the business card | Often continues until the card is restricted |
The pattern is consistent: anything new, large, or cross border is where the pause lands. That is precisely where supplier payments sit, which is why a review feels like a supply chain problem rather than a banking one.
A Seven Step Continuity Plan
This is the sequence that keeps goods moving while the review runs.
1. Confirm what is actually blocked
Ask the reviewer one direct question: which payment types are paused, and which still work. Do not assume everything is frozen. Some reviews restrict international transfers only, leaving domestic payments and card spending available.
2. Rank payments by consequence
List every open payment and score it by what happens if it is late. Demurrage and storage charges, a production slot, a deposit deadline, and a salary run all sit above a routine restocking order. Pay in that order, not in invoice date order.
3. Activate a second verified account
A business should never depend on one account for outbound payments. A second account, opened and verified months earlier, is the single most useful piece of contingency planning available. Opening one during a review is far harder, because the new institution will ask the same questions with less context.
4. Split the payment stack
Where a supplier allows it, separate the deposit from the balance. A deposit released against a proforma invoice keeps production moving, while the balance waits for documents. Staged payments are normal in trade and most suppliers will accept them when the reason is explained early.
5. Put everything in writing
Tell each affected supplier the same day, in one short message: what happened, which payment is affected, when you expect to release it, and what you need from them in the meantime. Suppliers tolerate delays they understand. They escalate delays they discover.
6. Protect the shipment release
The payment is only half the risk. Documents control the cargo. Confirm who holds the bill of lading, whether the release is against payment or against acceptance, and whether the freight forwarder needs a fresh instruction. Our guide to standby letters of credit explains how a bank instrument can cover performance when cash movement is temporarily restricted.
7. Keep a review log
Record every request, every document sent, and every response with dates. When a review is escalated internally, a clean log is the difference between a decision in days and a decision in weeks.
The Document Pack That Closes a Review Faster
Assemble this once and keep it current. It covers almost every request a reviewer will make.
- Certificate of incorporation and current registry extract
- Ownership and control chart, with identification for each significant controller
- Trading licence or sector registration
- Two or three recent supplier contracts, with matching invoices
- Shipping documents for goods in transit: commercial invoice, packing list, bill of lading
- Bank statements for the last six to twelve months, labelled by month
- Tax registration and, where relevant, tax clearance certificate
- A short written explanation of the business model, one page, in plain language
- Counterparty details for each new beneficiary: legal name, address, bank, and purpose of payment
Keep the file as a single dated folder. When a request arrives, you reply with the whole folder and a note naming each item. Reviewers close files faster when they are not chasing.
How to Talk to Your Bank Without Making It Worse
Tone matters less than structure.
- Use one channel and one thread. Repeated calls to different teams create duplicate notes and slow decisions.
- Ask for the specific document list in writing, and for a case reference.
- Answer the question asked, then stop. Volunteering unrelated detail invites new questions.
- Give one clear business explanation of the payment, with the contract and invoice attached.
- Ask what happens next and when, and record the answer.
Do not threaten to close the account. It does not speed up a compliance decision, and it can be logged as a risk indicator.
What Not to Do While Under Review
Some reactions turn a review into a closure.
- Splitting a payment to stay under a threshold. This is structuring, and it is treated as a red flag rather than a workaround.
- Routing business payments through a friend, agent, or staff account. Third party accounts break the audit trail and can trigger a suspicious activity report under the same FCA rules.
- Opening five new accounts at once. Multiple simultaneous applications look like an attempt to find a weaker control.
- Ignoring a request and hoping it closes. Files without responses stay open.
- Moving business flows into cash. It removes the traceability that resolves reviews.
How to Move the Next Payment Without Breaking the Relationship
When the review has no clear end date and a supplier needs money this week, the practical answer is a second route that settles on conventional rails and can be documented cleanly.
DapsyPay is built for exactly this situation. Payments run on standard international rails such as SEPA and ACH, there are no limits on transfer size, and the platform is designed for bulk sending by business owners rather than one off consumer transfers. Fees are shown before you send, currency conversion is priced into the quote instead of hidden in the rate, and funds are delivered to the supplier's bank account directly. Because every payment carries a clear reference and a matching document trail, it also gives you something to hand your reviewer later.
That is the difference between solving this week and solving the quarter. A single transfer platform that handles several supplier payments in one batch also means one set of documents instead of ten.
Businesses that pay several suppliers in different currencies often pair this with a card for small subscriptions, which is a different tool with different limits. Our explainer on virtual dollar cards covers where a card works and where it quietly fails on larger invoices.
What a Freeze Really Costs
The visible cost of a paused payment is the transfer fee you did not pay. The real cost sits elsewhere.
- Demurrage and storage. Cargo that cannot be released starts accumulating daily charges at the port.
- Lost production slots. Factories allocate capacity in sequence. A missed deposit moves you to the back of the queue.
- Penalty clauses. Many supply contracts carry late payment terms that activate after a stated number of days.
- Currency drift. A payment delayed by three weeks is exposed to three weeks of rate movement, which on a large order can cost more than every fee combined.
- Supplier trust. A supplier who has to chase once will quote a higher price next time, or ask for full payment upfront.
Common Mistakes
- Assuming a review means the account is closed and stopping all communication
- Sending partial documents and waiting to be asked again
- Paying a new beneficiary before checking the account name matches the contract
- Leaving the second account unopened until it is needed
- Failing to tell suppliers, then losing a shipment slot without warning
- Using personal accounts to keep business payments running
- Forgetting that incoming credits can also be held, and planning cash flow on the assumption they will land
FAQ
Conclusion
An account review is a documentation event, not a verdict. The businesses that come through it with their supply chain intact are the ones that already have a second route for outbound payments, a folder of documents ready to send, and a habit of telling suppliers the truth early.
Build the file this week. Open the second account before you need it. Rank the payments by what a delay actually costs. Then a review becomes an inconvenience rather than a crisis.
Related Guides
- How to Pay for ChatGPT Plus
- What Is a Standby Letter of Credit
- What Is a Virtual Dollar Card
- What to Do When a Payment Reference Is Missing
Keep Payments Moving During a Review
Send supplier payments on conventional rails with the rate shown upfront, no limits, and delivery straight to the supplier bank account.
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