[DRAFT] Not approved for publication. Every regulatory and safeguarding statement on this page needs compliance sign-off.

Know who you are paying

Most payment problems begin before the payment. A charity sends money to an account it has not verified, on the strength of an email, and the difficulties start later.

Before a first payment, hold a file on the partner containing:

• The legal name, registration number and registered address.

• Names of directors, trustees or beneficial owners.

• Bank details, confirmed by voice with a known contact.

• A signed agreement setting out what the money is for.

• A named person on each side who owns the relationship.

Confirm any change of bank details by telephone, using a number you already hold rather than one in the email requesting the change. Invoice redirection fraud is common and it usually arrives as an ordinary-looking message from a real address.

Sanctions and screening

Payments to sanctioned individuals, entities or territories are prohibited, and the obligation does not disappear because a bank or provider sits in the middle. Screening is normally performed by the regulated firm executing the payment, as part of its own obligations. [CONFIRM: who performs sanctions screening on payments arranged through Charitytransfers.org, and what may be stated here]

Your own checks matter too. Keep a dated record of the screening you carry out on new partners, keep it proportionate to the risk of the country and the size of the payment, and repeat it periodically rather than once at onboarding.

Where the money sits before it moves

Between leaving your account and reaching your partner, the money sits with the firm executing the payment. How it is held there is a question trustees are entitled to ask.

Two points to establish for any provider:

• That it is authorised by the Financial Conduct Authority as a payment institution or an electronic money institution, and that you have checked the Financial Services Register entry yourself.

• That client funds are safeguarded in segregated accounts, kept apart from the firm's own money at all times.

[CONFIRM: the exact safeguarding wording that may be used, and whether the PSD2 client trust account statement from the current site is still accurate]

Segregation matters most in the situation nobody plans for. If the firm fails, safeguarded client money is not available to its creditors in the same way as its own funds.

The paper trail auditors and trustees want

Three documents per payment, kept together, will answer almost every question an auditor asks.

• Rate confirmation. The rate agreed, the amount converted, the time and date.

• Payment confirmation. Proof that funds were sent, and to which account.

• Monthly statement. Every payment for the month, with its verified cost.

To that, add the partner file and the screening record. Keep them where a finance officer can retrieve them without asking anyone, because the request usually arrives at the busiest point of the year.

The reason to keep rate confirmations, rather than only payment confirmations, is that they are the only evidence of what the conversion cost. A payment confirmation shows the money left. It does not show whether the rate was fair.

Where payments go wrong

The money arrives short

The most common complaint, and usually the least explained. Either a second conversion happened at the far end at a rate nobody agreed, or a bank in the chain took a charge. Ask the partner for their receipt advice; it normally names the deduction.

Correspondent banks take a cut

A payment to a hard-to-reach country may pass through two or three banks. Any of them can deduct a charge in transit. Ask your provider which charging option applies, and whether the corridor can be paid locally instead of routed through correspondents.

The payment is late

Cut-off times, public holidays in the destination country, and compliance checks on a new beneficiary all add days. Build the first payment to any new partner into the timetable with a week of slack, and expect the second to be faster.

Before the next payment run

• Check the provider's Financial Services Register entry.

• Confirm bank details by voice for any new or changed account.

• File the rate confirmation alongside the payment confirmation.

• Ask the partner to confirm the amount received.

• Chase any shortfall while the receipt advice is still available.

If a shortfall keeps recurring on the same corridor, the routing is usually the cause rather than the partner. We are glad to look at it with you. [CONFIRM: how this service may be described]