[{"data":1,"prerenderedAt":741},["ShallowReactive",2],{"content-\u002Fresources\u002Fmore\u002Fcross-border-payout-rfi-how-to-answer":3,"resources-category-cross-border-payout-rfi-how-to-answer":530},{"id":4,"title":5,"authors":6,"body":7,"categories":6,"category":479,"categoryType":6,"compare":6,"contributors":6,"date":480,"description":481,"extension":482,"faq":483,"howto":502,"isBlog":520,"isChangelog":520,"meta":521,"navigation":523,"path":524,"pillar":520,"products":6,"rawbody":525,"role":6,"seo":526,"seoTitle":527,"stem":528,"thumbnail":6,"updated":480,"__hash__":529},"content\u002Fresources\u002Fmore\u002Fcross-border-payout-rfi-how-to-answer.md","Why did my cross-border payout get an RFI? What compliance asks, and how to answer fast",null,{"type":8,"value":9,"toc":466},"minimark",[10,14,23,29,57,62,65,168,186,197,201,211,220,229,233,236,253,256,264,268,271,286,294,302,306,309,341,348,352,360,416,428,432,440,443,447,456,460],[11,12,13],"p",{},"A cross-border payout gets an RFI when compliance needs more information before it can approve a customer or release a transaction. A request for information (RFI) is a structured list of questions and document uploads. Answer it completely and fast: a customer RFI auto-rejects after 27 days, and a held transaction should be answered within 24 hours.",[11,15,16,17,22],{},"RFIs are part of why cross-border payments carry compliance cost at all. In the ",[18,19,21],"a",{"href":20},"\u002Fresources\u002Fmore\u002Fwhat-is-a-stablecoin-sandwich","stablecoin sandwich",", the on-chain leg is cheap, but the on-ramp and off-ramp still run full KYC, KYB, and monitoring. RFIs are where that work reaches your team.",[11,24,25],{},[26,27,28],"strong",{},"Key takeaways",[30,31,32,36,48,51,54],"ul",{},[33,34,35],"li",{},"There are three kinds of RFI: about a customer, about a held transaction, and about your own company. Each has its own deadline.",[33,37,38,39,43,44,47],{},"A customer in ",[40,41,42],"code",{},"compliance_request"," can't transact. A customer in ",[40,45,46],{},"approved_rfi"," keeps working while you answer.",[33,49,50],{},"BlindPay emails your team, not your customer. Collecting the answer is your job.",[33,52,53],{},"Submissions are single-shot. Read every section first and match the exact document type requested.",[33,55,56],{},"The fastest RFI is the one you prevent: complete, consistent onboarding data up front.",[58,59,61],"h2",{"id":60},"what-are-the-three-kinds-of-rfi","What are the three kinds of RFI?",[11,63,64],{},"They differ by subject, by deadline, and by what they block.",[66,67,68,90],"table",{},[69,70,71],"thead",{},[72,73,74,78,81,84,87],"tr",{},[75,76,77],"th",{},"RFI type",[75,79,80],{},"What it's about",[75,82,83],{},"Effect while open",[75,85,86],{},"Deadline",[75,88,89],{},"If you miss it",[91,92,93,114,132,152],"tbody",{},[72,94,95,99,102,108,111],{},[96,97,98],"td",{},"Customer RFI, blocking",[96,100,101],{},"One of your customers' KYC or KYB",[96,103,104,105,107],{},"Customer can't send or receive (",[40,106,42],{},")",[96,109,110],{},"27 days",[96,112,113],{},"Customer auto-rejected",[72,115,116,119,122,127,129],{},[96,117,118],{},"Customer RFI, non-blocking",[96,120,121],{},"Periodic review of an approved customer",[96,123,124,125,107],{},"Customer keeps full access (",[40,126,46],{},[96,128,110],{},[96,130,131],{},"Compliance reviews the case manually",[72,133,134,137,140,146,149],{},[96,135,136],{},"Transaction hold RFI",[96,138,139],{},"One flagged payin or payout",[96,141,142,143],{},"That transaction stays ",[40,144,145],{},"on_hold",[96,147,148],{},"24 hours",[96,150,151],{},"Transaction may be refunded to the sender",[72,153,154,157,160,163,165],{},[96,155,156],{},"Instance RFI",[96,158,159],{},"Your own company",[96,161,162],{},"No effect on your account or payments",[96,164,110],{},[96,166,167],{},"Request expires, compliance follows up",[11,169,170,171,175,176,180,181,185],{},"Sources: BlindPay's ",[18,172,174],{"href":173},"\u002Fdocs\u002Fkb\u002Finformation-requests","information requests",", ",[18,177,179],{"href":178},"\u002Fdocs\u002Fkb\u002Fon-hold-transactions","on-hold transactions",", and ",[18,182,184],{"href":183},"\u002Fdocs\u002Fkb\u002Finstance-requests","instance requests"," guides.",[11,187,188,189,191,192,196],{},"SWIFT document reviews look similar but aren't RFIs. Every SWIFT payout starts ",[40,190,145],{},", and third-party SWIFT payouts wait for a document such as an invoice or contract. ",[18,193,195],{"href":194},"\u002Fresources\u002Fmore\u002Fhow-to-send-swift-payout-from-usdc","How to send a SWIFT payout from USDC"," covers that flow.",[58,198,200],{"id":199},"why-do-compliance-teams-send-rfis-at-all","Why do compliance teams send RFIs at all?",[11,202,203,204,210],{},"Because the rules require them to understand who they serve and why money moves. FinCEN's ",[18,205,209],{"href":206,"rel":207},"https:\u002F\u002Fwww.fincen.gov\u002Fresources\u002Fstatutes-and-regulations\u002Fcdd-final-rule",[208],"nofollow","customer due diligence rule"," asks covered institutions to \"understand the nature and purpose of customer relationships\" and, on a risk basis, to \"maintain and update customer information.\" An RFI is how a payment provider closes a gap in that file without rejecting the customer.",[11,212,213,214,219],{},"Cross-border payments also carry more data than domestic ones. FATF adopted a ",[18,215,218],{"href":216,"rel":217},"https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Fpublications\u002FFatfrecommendations\u002Fupdate-Recommendation-16-payment-transparency-june-2025.html",[208],"revised Recommendation 16"," on payment transparency in June 2025, with implementation expected by the end of 2030, so expect data requests on cross-border flows to grow, not shrink.",[11,221,222,223,228],{},"The traditional system duplicates this work. The Federal Reserve's ",[18,224,227],{"href":225,"rel":226},"https:\u002F\u002Fwww.federalreserve.gov\u002Feconres\u002Fnotes\u002Ffeds-notes\u002Fpayment-stablecoins-and-cross-border-payments-benefits-and-implications-for-monetary-policy-20260330.html",[208],"March 30, 2026 FEDS Note"," notes that compliance checks can run \"at multiple points in the chain\" of correspondent banks. A stablecoin payout shortens the chain, but the checks at each end stay.",[58,230,232],{"id":231},"what-does-a-customer-rfi-usually-ask-for","What does a customer RFI usually ask for?",[11,234,235],{},"The gaps that block a clean KYC or KYB decision. BlindPay's docs list these common triggers:",[30,237,238,241,244,247,250],{},[33,239,240],{},"A business description that doesn't match the company's website or industry",[33,242,243],{},"A proof of address that doesn't match the registered address",[33,245,246],{},"An identity document that's expired, blurry, or partially visible",[33,248,249],{},"An ownership structure that needs an updated share register or UBO documentation",[33,251,252],{},"Source of funds or source of wealth that needs evidence",[11,254,255],{},"Each RFI arrives as sections. Every section has a title, a description of what compliance needs, and one or more fields: text, a file upload, or a dropdown. One RFI can mix a document upload with a written explanation.",[11,257,258,259,263],{},"Source of funds is the trigger teams find hardest to answer. ",[18,260,262],{"href":261},"\u002Fresources\u002Fmore\u002Fsource-of-funds-crypto-off-ramps","Why off-ramps ask for source of funds"," lists the documents that work and the ones that fail.",[58,265,267],{"id":266},"what-does-a-transaction-hold-rfi-ask-for","What does a transaction hold RFI ask for?",[11,269,270],{},"The story behind one payment. When monitoring flags a payin or payout and compliance can't clear it internally, BlindPay sends the transaction details and asks for:",[272,273,274,277,280,283],"ol",{},[33,275,276],{},"The relationship between the sender and the customer",[33,278,279],{},"The purpose of the transaction",[33,281,282],{},"The expected outcome of the transaction",[33,284,285],{},"Anything else that helps explain it",[11,287,288,289,293],{},"The clock here is short. If the RFI isn't answered within 24 hours, the transaction may be refunded to the sender. Holds in general can last up to 30 days, and a hold that times out without a decision fails the transaction (",[18,290,292],{"href":291},"\u002Fdocs\u002Fkb\u002Fcut-off-times","cut-off times and compliance holds",").",[11,295,296,297,301],{},"Write the answer the way you'd explain it to a new finance hire. \"Monthly invoice 2026-091 from our design contractor in Curitiba, per the attached contract\" beats \"business payment.\" ",[18,298,300],{"href":299},"\u002Fresources\u002Fmore\u002Freduce-false-positives-transaction-monitoring","How to reduce false positives in transaction monitoring"," explains why vague answers lead to second rounds.",[58,303,305],{"id":304},"how-do-you-answer-an-rfi-the-first-time","How do you answer an RFI the first time?",[11,307,308],{},"Five habits cut most second rounds:",[272,310,311,317,323,329,335],{},[33,312,313,316],{},[26,314,315],{},"Start on day 0."," BlindPay sends an Action Required email on day 0, a reminder on day 7, a final notice on day 17, and the rejection on day 27. Most misses happen because the customer wasn't reached in time.",[33,318,319,322],{},[26,320,321],{},"Match the format exactly."," If a section asks for a utility bill, a bank statement won't satisfy it. Re-read every description before uploading.",[33,324,325,328],{},[26,326,327],{},"Keep documents consistent."," Names, addresses, and ownership percentages should match across the share register, the IDs, and the application.",[33,330,331,334],{},[26,332,333],{},"Submit once, completely."," The submission is single-shot, and the dashboard won't send until every required field is filled.",[33,336,337,340],{},[26,338,339],{},"Route emails to the right people."," RFI emails go to every active member of your instance unless you set dedicated compliance addresses (up to 20) in settings. Remove former teammates.",[11,342,343,344,347],{},"After you submit, the customer's status returns to ",[40,345,346],{},"verifying"," and compliance re-reviews. BlindPay's docs say most RFIs resolve within a few business days. If something is still missing, a new RFI opens. Only one can be open per customer at a time.",[58,349,351],{"id":350},"how-do-you-handle-rfis-through-the-api","How do you handle RFIs through the API?",[11,353,354,355,359],{},"Treat them as a status change, not an email. The flow from BlindPay's ",[18,356,358],{"href":357},"\u002Fdocs\u002Flearn\u002Frfi","RFI API docs",":",[272,361,362,369,390,393,400],{},[33,363,364,365,368],{},"Subscribe to the ",[40,366,367],{},"customer.update"," webhook.",[33,370,371,372,375,376,378,379,381,382,385,386,389],{},"When ",[40,373,374],{},"kyc_status"," becomes ",[40,377,42],{}," or ",[40,380,46],{},", call ",[40,383,384],{},"GET \u002Fv1\u002Finstances\u002F{instance_id}\u002Fcustomers\u002F{customer_id}\u002Frfi",". It returns the open RFI, or ",[40,387,388],{},"null"," when none is open.",[33,391,392],{},"Render the requested fields in your own interface and collect them from your customer.",[33,394,395,396,399],{},"Submit everything in one ",[40,397,398],{},"POST"," to the same path.",[33,401,402,403,405,406,175,409,412,413,415],{},"Wait for the next ",[40,404,367],{},": ",[40,407,408],{},"approved",[40,410,411],{},"rejected",", or another ",[40,414,42],{},".",[11,417,418,419,422,423,427],{},"The RFI payload includes ",[40,420,421],{},"expires_at",", so your system can show the deadline and nudge the customer before day 17. Building this in-product beats forwarding emails, because the person who has the documents sees the request directly. ",[18,424,426],{"href":425},"\u002Fresources\u002Fmore\u002Fhow-to-automate-kyc-kyb-stablecoin-payments","How to automate KYC and KYB"," covers the onboarding side of the same integration.",[58,429,431],{"id":430},"how-do-you-prevent-rfis-in-the-first-place","How do you prevent RFIs in the first place?",[11,433,434,435,439],{},"Front-load the data compliance would otherwise ask for. A website that describes the actual business, a proof of address dated within 90 days, a share register that names every UBO with percentages, and IDs that are current and fully visible remove most of the triggers above. BlindPay's ",[18,436,438],{"href":437},"\u002Fdocs\u002Fkb\u002Fkyb-documents","KYB documents guide"," lists the exact requirements.",[11,441,442],{},"For transactions, consistency is the prevention. A customer whose payments match the volume and counterparties described at onboarding trips fewer flags than one whose activity drifts.",[58,444,446],{"id":445},"how-does-blindpay-handle-rfis","How does BlindPay handle RFIs?",[11,448,449,450,452,453,455],{},"BlindPay compliance opens an RFI instead of rejecting outright when a customer file or a transaction needs context. You get it in the dashboard, by email to your team or your compliance list, and through the ",[40,451,367],{}," webhook, with a fetch and submit endpoint for in-product handling. Customer RFIs run 27 days with reminders on days 7 and 17. Non-blocking ",[40,454,46],{}," reviews let approved customers keep sending payouts over Pix, SPEI, ACH, SEPA, or SWIFT (POBO\u002FCOBO) while you answer. Held transactions ask for relationship and purpose and should be answered within 24 hours.",[58,457,459],{"id":458},"what-to-do-next","What to do next",[11,461,462,463,465],{},"Check who receives compliance email on your instance today, and set a dedicated compliance address list if it's still going to the whole team. Then subscribe to ",[40,464,367],{}," on a development instance and wire the RFI fetch into your support tooling before the first real one arrives.",{"title":467,"searchDepth":468,"depth":468,"links":469},"",2,[470,471,472,473,474,475,476,477,478],{"id":60,"depth":468,"text":61},{"id":199,"depth":468,"text":200},{"id":231,"depth":468,"text":232},{"id":266,"depth":468,"text":267},{"id":304,"depth":468,"text":305},{"id":350,"depth":468,"text":351},{"id":430,"depth":468,"text":431},{"id":445,"depth":468,"text":446},{"id":458,"depth":468,"text":459},"compliance","2026-10-13","A request for information pauses a customer or holds a payout until compliance gets answers. The three RFI types, their deadlines, and how to answer.","md",[484,487,490,493,496,499],{"q":485,"a":486},"What is an RFI in cross-border payments?","A request for information is how a payment provider's compliance team asks for missing or clarifying details instead of rejecting a customer or a transaction outright. It might ask for an updated proof of address, ownership documents, source of funds, or the purpose of a specific payment. The customer or transaction waits until the answer arrives and compliance reviews it.",{"q":488,"a":489},"How long do I have to answer an RFI on BlindPay?","A customer RFI gives you 27 days, with reminder emails on days 7 and 17, and auto-rejects a paused customer when the deadline passes. A request about a held transaction should be answered within 24 hours, or the transaction may be refunded to the sender. An instance RFI about your own company also runs 27 days but doesn't block payments.",{"q":491,"a":492},"Can a customer keep sending payments while an RFI is open?","It depends on the status. A customer in compliance_request can't send or receive funds until the response is reviewed. A customer in approved_rfi keeps full access, including payouts, payins, and virtual accounts, and returns to approved as soon as you submit. The approved_rfi type is typically used for periodic reviews of customers who are already approved.",{"q":494,"a":495},"Why does BlindPay email my team instead of my customer?","Because collecting the documents is the partner's job. BlindPay emails every active member of your instance, or only the compliance addresses you configure, up to 20. You then reach your customer through your own product and upload the response. Keeping the member list current stops RFIs from landing in a former teammate's inbox.",{"q":497,"a":498},"What are the most common reasons for an RFI?","BlindPay's docs list a business description that doesn't match the company's website, a proof of address that doesn't match the registered address, an expired or blurry ID, ownership structures that need an updated share register or UBO documents, and source of funds or wealth that needs evidence. Held transactions usually need the sender relationship and purpose.",{"q":500,"a":501},"Can I answer an RFI through the API?","Yes. Subscribe to the customer.update webhook, fetch the open RFI with GET \u002Fv1\u002Finstances\u002F{instance_id}\u002Fcustomers\u002F{customer_id}\u002Frfi, collect the fields in your own interface, and submit them in one POST to the same path. Only one RFI can be open per customer, and the payload includes expires_at so your system can track the deadline.",{"name":503,"steps":504},"How to answer a request for information on a cross-border payment",[505,508,511,514,517],{"name":506,"text":507},"Identify which kind of RFI it is","Check whether it is about a customer (kyc_status compliance_request or approved_rfi), about a held transaction (payout or payin on_hold), or about your own company (an instance RFI). Each has a different deadline and a different effect on payments.",{"name":509,"text":510},"Read every section before collecting anything","Each RFI lists sections with a title, a description of what compliance needs, and the fields to fill in. Match the exact document type requested; a bank statement does not satisfy a request for a utility bill.",{"name":512,"text":513},"Collect documents from your customer early","You, not BlindPay, contact your customer. Start on day 0, since a customer RFI auto-rejects after 27 days and a transaction RFI should be answered within 24 hours.",{"name":515,"text":516},"Submit the whole response at once","Submissions are single-shot: fill every required field, upload the files, and submit in one action from the dashboard or with POST \u002Fv1\u002Finstances\u002F{instance_id}\u002Fcustomers\u002F{customer_id}\u002Frfi.",{"name":518,"text":519},"Watch for the next status change","Listen for the customer.update webhook. The customer moves back to verifying, then to approved, rejected, or a new compliance_request if compliance needs another round.",false,{"author":522},"BlindPay Team",true,"\u002Fresources\u002Fmore\u002Fcross-border-payout-rfi-how-to-answer","---\ntitle: \"Why did my cross-border payout get an RFI? What compliance asks, and how to answer fast\"\nseoTitle: \"Cross-border payout RFI: what's asked and how to answer\"\ndescription: \"A request for information pauses a customer or holds a payout until compliance gets answers. The three RFI types, their deadlines, and how to answer.\"\ndate: \"2026-10-13\"\nupdated: \"2026-10-13\"\ncategory: \"compliance\"\nauthor: \"BlindPay Team\"\nhowto:\n  name: \"How to answer a request for information on a cross-border payment\"\n  steps:\n    - name: \"Identify which kind of RFI it is\"\n      text: \"Check whether it is about a customer (kyc_status compliance_request or approved_rfi), about a held transaction (payout or payin on_hold), or about your own company (an instance RFI). Each has a different deadline and a different effect on payments.\"\n    - name: \"Read every section before collecting anything\"\n      text: \"Each RFI lists sections with a title, a description of what compliance needs, and the fields to fill in. Match the exact document type requested; a bank statement does not satisfy a request for a utility bill.\"\n    - name: \"Collect documents from your customer early\"\n      text: \"You, not BlindPay, contact your customer. Start on day 0, since a customer RFI auto-rejects after 27 days and a transaction RFI should be answered within 24 hours.\"\n    - name: \"Submit the whole response at once\"\n      text: \"Submissions are single-shot: fill every required field, upload the files, and submit in one action from the dashboard or with POST \u002Fv1\u002Finstances\u002F{instance_id}\u002Fcustomers\u002F{customer_id}\u002Frfi.\"\n    - name: \"Watch for the next status change\"\n      text: \"Listen for the customer.update webhook. The customer moves back to verifying, then to approved, rejected, or a new compliance_request if compliance needs another round.\"\nfaq:\n  - q: \"What is an RFI in cross-border payments?\"\n    a: \"A request for information is how a payment provider's compliance team asks for missing or clarifying details instead of rejecting a customer or a transaction outright. It might ask for an updated proof of address, ownership documents, source of funds, or the purpose of a specific payment. The customer or transaction waits until the answer arrives and compliance reviews it.\"\n  - q: \"How long do I have to answer an RFI on BlindPay?\"\n    a: \"A customer RFI gives you 27 days, with reminder emails on days 7 and 17, and auto-rejects a paused customer when the deadline passes. A request about a held transaction should be answered within 24 hours, or the transaction may be refunded to the sender. An instance RFI about your own company also runs 27 days but doesn't block payments.\"\n  - q: \"Can a customer keep sending payments while an RFI is open?\"\n    a: \"It depends on the status. A customer in compliance_request can't send or receive funds until the response is reviewed. A customer in approved_rfi keeps full access, including payouts, payins, and virtual accounts, and returns to approved as soon as you submit. The approved_rfi type is typically used for periodic reviews of customers who are already approved.\"\n  - q: \"Why does BlindPay email my team instead of my customer?\"\n    a: \"Because collecting the documents is the partner's job. BlindPay emails every active member of your instance, or only the compliance addresses you configure, up to 20. You then reach your customer through your own product and upload the response. Keeping the member list current stops RFIs from landing in a former teammate's inbox.\"\n  - q: \"What are the most common reasons for an RFI?\"\n    a: \"BlindPay's docs list a business description that doesn't match the company's website, a proof of address that doesn't match the registered address, an expired or blurry ID, ownership structures that need an updated share register or UBO documents, and source of funds or wealth that needs evidence. Held transactions usually need the sender relationship and purpose.\"\n  - q: \"Can I answer an RFI through the API?\"\n    a: \"Yes. Subscribe to the customer.update webhook, fetch the open RFI with GET \u002Fv1\u002Finstances\u002F{instance_id}\u002Fcustomers\u002F{customer_id}\u002Frfi, collect the fields in your own interface, and submit them in one POST to the same path. Only one RFI can be open per customer, and the payload includes expires_at so your system can track the deadline.\"\n---\n\nA cross-border payout gets an RFI when compliance needs more information before it can approve a customer or release a transaction. A request for information (RFI) is a structured list of questions and document uploads. Answer it completely and fast: a customer RFI auto-rejects after 27 days, and a held transaction should be answered within 24 hours.\n\nRFIs are part of why cross-border payments carry compliance cost at all. In the [stablecoin sandwich](\u002Fresources\u002Fmore\u002Fwhat-is-a-stablecoin-sandwich), the on-chain leg is cheap, but the on-ramp and off-ramp still run full KYC, KYB, and monitoring. RFIs are where that work reaches your team.\n\n**Key takeaways**\n\n- There are three kinds of RFI: about a customer, about a held transaction, and about your own company. Each has its own deadline.\n- A customer in `compliance_request` can't transact. A customer in `approved_rfi` keeps working while you answer.\n- BlindPay emails your team, not your customer. Collecting the answer is your job.\n- Submissions are single-shot. Read every section first and match the exact document type requested.\n- The fastest RFI is the one you prevent: complete, consistent onboarding data up front.\n\n## What are the three kinds of RFI?\n\nThey differ by subject, by deadline, and by what they block.\n\n| RFI type | What it's about | Effect while open | Deadline | If you miss it |\n| --- | --- | --- | --- | --- |\n| Customer RFI, blocking | One of your customers' KYC or KYB | Customer can't send or receive (`compliance_request`) | 27 days | Customer auto-rejected |\n| Customer RFI, non-blocking | Periodic review of an approved customer | Customer keeps full access (`approved_rfi`) | 27 days | Compliance reviews the case manually |\n| Transaction hold RFI | One flagged payin or payout | That transaction stays `on_hold` | 24 hours | Transaction may be refunded to the sender |\n| Instance RFI | Your own company | No effect on your account or payments | 27 days | Request expires, compliance follows up |\n\nSources: BlindPay's [information requests](\u002Fdocs\u002Fkb\u002Finformation-requests), [on-hold transactions](\u002Fdocs\u002Fkb\u002Fon-hold-transactions), and [instance requests](\u002Fdocs\u002Fkb\u002Finstance-requests) guides.\n\nSWIFT document reviews look similar but aren't RFIs. Every SWIFT payout starts `on_hold`, and third-party SWIFT payouts wait for a document such as an invoice or contract. [How to send a SWIFT payout from USDC](\u002Fresources\u002Fmore\u002Fhow-to-send-swift-payout-from-usdc) covers that flow.\n\n## Why do compliance teams send RFIs at all?\n\nBecause the rules require them to understand who they serve and why money moves. FinCEN's [customer due diligence rule](https:\u002F\u002Fwww.fincen.gov\u002Fresources\u002Fstatutes-and-regulations\u002Fcdd-final-rule) asks covered institutions to \"understand the nature and purpose of customer relationships\" and, on a risk basis, to \"maintain and update customer information.\" An RFI is how a payment provider closes a gap in that file without rejecting the customer.\n\nCross-border payments also carry more data than domestic ones. FATF adopted a [revised Recommendation 16](https:\u002F\u002Fwww.fatf-gafi.org\u002Fen\u002Fpublications\u002FFatfrecommendations\u002Fupdate-Recommendation-16-payment-transparency-june-2025.html) on payment transparency in June 2025, with implementation expected by the end of 2030, so expect data requests on cross-border flows to grow, not shrink.\n\nThe traditional system duplicates this work. The Federal Reserve's [March 30, 2026 FEDS Note](https:\u002F\u002Fwww.federalreserve.gov\u002Feconres\u002Fnotes\u002Ffeds-notes\u002Fpayment-stablecoins-and-cross-border-payments-benefits-and-implications-for-monetary-policy-20260330.html) notes that compliance checks can run \"at multiple points in the chain\" of correspondent banks. A stablecoin payout shortens the chain, but the checks at each end stay.\n\n## What does a customer RFI usually ask for?\n\nThe gaps that block a clean KYC or KYB decision. BlindPay's docs list these common triggers:\n\n- A business description that doesn't match the company's website or industry\n- A proof of address that doesn't match the registered address\n- An identity document that's expired, blurry, or partially visible\n- An ownership structure that needs an updated share register or UBO documentation\n- Source of funds or source of wealth that needs evidence\n\nEach RFI arrives as sections. Every section has a title, a description of what compliance needs, and one or more fields: text, a file upload, or a dropdown. One RFI can mix a document upload with a written explanation.\n\nSource of funds is the trigger teams find hardest to answer. [Why off-ramps ask for source of funds](\u002Fresources\u002Fmore\u002Fsource-of-funds-crypto-off-ramps) lists the documents that work and the ones that fail.\n\n## What does a transaction hold RFI ask for?\n\nThe story behind one payment. When monitoring flags a payin or payout and compliance can't clear it internally, BlindPay sends the transaction details and asks for:\n\n1. The relationship between the sender and the customer\n2. The purpose of the transaction\n3. The expected outcome of the transaction\n4. Anything else that helps explain it\n\nThe clock here is short. If the RFI isn't answered within 24 hours, the transaction may be refunded to the sender. Holds in general can last up to 30 days, and a hold that times out without a decision fails the transaction ([cut-off times and compliance holds](\u002Fdocs\u002Fkb\u002Fcut-off-times)).\n\nWrite the answer the way you'd explain it to a new finance hire. \"Monthly invoice 2026-091 from our design contractor in Curitiba, per the attached contract\" beats \"business payment.\" [How to reduce false positives in transaction monitoring](\u002Fresources\u002Fmore\u002Freduce-false-positives-transaction-monitoring) explains why vague answers lead to second rounds.\n\n## How do you answer an RFI the first time?\n\nFive habits cut most second rounds:\n\n1. **Start on day 0.** BlindPay sends an Action Required email on day 0, a reminder on day 7, a final notice on day 17, and the rejection on day 27. Most misses happen because the customer wasn't reached in time.\n2. **Match the format exactly.** If a section asks for a utility bill, a bank statement won't satisfy it. Re-read every description before uploading.\n3. **Keep documents consistent.** Names, addresses, and ownership percentages should match across the share register, the IDs, and the application.\n4. **Submit once, completely.** The submission is single-shot, and the dashboard won't send until every required field is filled.\n5. **Route emails to the right people.** RFI emails go to every active member of your instance unless you set dedicated compliance addresses (up to 20) in settings. Remove former teammates.\n\nAfter you submit, the customer's status returns to `verifying` and compliance re-reviews. BlindPay's docs say most RFIs resolve within a few business days. If something is still missing, a new RFI opens. Only one can be open per customer at a time.\n\n## How do you handle RFIs through the API?\n\nTreat them as a status change, not an email. The flow from BlindPay's [RFI API docs](\u002Fdocs\u002Flearn\u002Frfi):\n\n1. Subscribe to the `customer.update` webhook.\n2. When `kyc_status` becomes `compliance_request` or `approved_rfi`, call `GET \u002Fv1\u002Finstances\u002F{instance_id}\u002Fcustomers\u002F{customer_id}\u002Frfi`. It returns the open RFI, or `null` when none is open.\n3. Render the requested fields in your own interface and collect them from your customer.\n4. Submit everything in one `POST` to the same path.\n5. Wait for the next `customer.update`: `approved`, `rejected`, or another `compliance_request`.\n\nThe RFI payload includes `expires_at`, so your system can show the deadline and nudge the customer before day 17. Building this in-product beats forwarding emails, because the person who has the documents sees the request directly. [How to automate KYC and KYB](\u002Fresources\u002Fmore\u002Fhow-to-automate-kyc-kyb-stablecoin-payments) covers the onboarding side of the same integration.\n\n## How do you prevent RFIs in the first place?\n\nFront-load the data compliance would otherwise ask for. A website that describes the actual business, a proof of address dated within 90 days, a share register that names every UBO with percentages, and IDs that are current and fully visible remove most of the triggers above. BlindPay's [KYB documents guide](\u002Fdocs\u002Fkb\u002Fkyb-documents) lists the exact requirements.\n\nFor transactions, consistency is the prevention. A customer whose payments match the volume and counterparties described at onboarding trips fewer flags than one whose activity drifts.\n\n## How does BlindPay handle RFIs?\n\nBlindPay compliance opens an RFI instead of rejecting outright when a customer file or a transaction needs context. You get it in the dashboard, by email to your team or your compliance list, and through the `customer.update` webhook, with a fetch and submit endpoint for in-product handling. Customer RFIs run 27 days with reminders on days 7 and 17. Non-blocking `approved_rfi` reviews let approved customers keep sending payouts over Pix, SPEI, ACH, SEPA, or SWIFT (POBO\u002FCOBO) while you answer. Held transactions ask for relationship and purpose and should be answered within 24 hours.\n\n## What to do next\n\nCheck who receives compliance email on your instance today, and set a dedicated compliance address list if it's still going to the whole team. Then subscribe to `customer.update` on a development instance and wire the RFI fetch into your support tooling before the first real one arrives.\n",{"title":5,"description":481},"Cross-border payout RFI: what's asked and how to answer","resources\u002Fmore\u002Fcross-border-payout-rfi-how-to-answer","pTgaoJ-0Z_79Z_r8z9GLFjiwIP5NciJQO5fyEZD5L40",[531,535,539,543,547,551,555,559,563,567,571,575,579,583,587,591,595,599,602,606,609,613,617,621,625,629,633,637,641,645,649,653,657,661,665,669,673,677,681,685,689,693,697,701,705,709,713,717,721,725,729,733,737,738],{"path":532,"title":533,"description":534},"\u002Fresources\u002Fmore\u002Faml-audit-readiness-risk-monitoring","AML audit readiness: what regulators ask for and how to prove your risk monitoring works","The evidence examiners expect from automated risk monitoring: a 10-item evidence table, good vs poor practice, SAR timelines, RFIs, and a 30-day plan.",{"path":536,"title":537,"description":538},"\u002Fresources\u002Fmore\u002Fneobank-remittance-feature-us-rules","Adding remittances to a US neobank: the Remittance Transfer Rule, disclosures, and pricing","How to add a low-fee remittance feature to a US neobank: when the Remittance Transfer Rule applies, disclosures, 30-minute cancellation, and pricing.",{"path":540,"title":541,"description":542},"\u002Fresources\u002Fmore\u002Fare-blockchain-payments-legal","Are blockchain payments legal? Rules in the US, EU, UK, Brazil, and Mexico","Blockchain payments are legal for businesses in the US, EU, UK, Brazil, and Mexico, under different rules. What each country regulates, as of October 2026.",{"path":544,"title":545,"description":546},"\u002Fresources\u002Fmore\u002Fare-stablecoin-card-purchases-taxable","Are stablecoin card purchases taxable? A country-by-country overview of disposals, gains, and records","Why a stablecoin card purchase can be a taxable disposal, how the US, UK, Germany, Spain, the Netherlands, and Brazil differ, and which records to keep.",{"path":548,"title":549,"description":550},"\u002Fresources\u002Fmore\u002Fare-stablecoin-payments-reversible","Are stablecoin payments reversible? Finality, custody, and fraud explained","Stablecoin transfers settle final in minutes and cannot be reversed. That finality proves custody at every step, but it also opens a fraud gap on the fiat side of the payment.",{"path":552,"title":553,"description":554},"\u002Fresources\u002Fmore\u002Fautomated-kyc-kyb-vs-manual-onboarding","Automated KYC\u002FKYB vs. manual onboarding: what actually changes","A side-by-side comparison of automated and manual KYC\u002FKYB for fintechs: onboarding time, false-positive rates, cost per verification, scaling across jurisdictions, and audit-trail quality, plus the cases where a human reviewer is still required.",{"path":556,"title":557,"description":558},"\u002Fresources\u002Fmore\u002Fbrazil-self-custody-wallet-declaration","Brazil's self-custody wallet rule: COAF reporting for transfers of US$10,000 or more","Since October 1, 2026, Brazil requires reports to COAF on transfers of US$10,000+ to or from self-custodied wallets. What counts, who reports, what to do.",{"path":560,"title":561,"description":562},"\u002Fresources\u002Fmore\u002Fbuild-vs-buy-automated-risk-monitoring","Build vs. buy automated risk monitoring: a decision framework and 15 provider questions","Build, buy point solutions, or use an integrated provider? Compare three ways to run automated risk monitoring, who stays responsible, and 15 questions.",{"path":564,"title":565,"description":566},"\u002Fresources\u002Fmore\u002Fcompliance-agents-cross-border-stablecoin-payments","Compliance agents for cross-border stablecoin payments: a global regulatory guide","How compliance agents apply FinCEN, MiCA, FCA, MAS, and Banco Central do Brasil rules to cross-border stablecoin payments: jurisdiction table, the FATF Travel Rule, multi-list sanctions screening, the four components of a compliant program, and questions to ask a compliance provider.",{"path":568,"title":569,"description":570},"\u002Fresources\u002Fmore\u002Fcross-border-stablecoin-card-compliance-by-country","Compliance for cross-border stablecoin card programs: a country readiness template","A country readiness template for stablecoin card programs: onboarding rules, funding rails, and payout rails for the US, LatAm, and the EU.",{"path":572,"title":573,"description":574},"\u002Fresources\u002Fmore\u002Fcross-border-stablecoin-payments-risk-register","Cross-border stablecoin payments risk register: a fill-in template with 16 risks, scores, and owners","A copyable risk register for cross-border stablecoin payouts: 16 risks across six categories, a 5x5 scoring method, controls, indicators, and owners.",{"path":576,"title":577,"description":578},"\u002Fresources\u002Fmore\u002Fcrypto-wallet-compliance-checklist","Crypto wallet compliance checklist: KYC, KYT, and Travel Rule","The compliance that comes with crypto wallets and stablecoin payments: KYC and KYB, KYT, the Travel Rule, address screening, MSB rules, and 15 checks.",{"path":580,"title":581,"description":582},"\u002Fresources\u002Fmore\u002Fdirect-vs-indirect-stablecoin-exchange","Direct vs indirect stablecoin exchange: who holds the stablecoin, and who carries compliance","In direct exchange, both parties hold stablecoins and own compliance. In indirect exchange, a provider settles in stablecoins behind a normal bank payment.",{"path":584,"title":585,"description":586},"\u002Fresources\u002Fmore\u002Fdo-merchants-need-a-license-to-accept-stablecoins","Do merchants need a license to accept stablecoin payments? KYC, KYB, and compliance explained","Usually no: the license sits with the provider that moves the funds. What merchants still owe on KYB, sanctions, tax, and records in the US, EU, Brazil.",{"path":588,"title":589,"description":590},"\u002Fresources\u002Fmore\u002Fdo-stablecoin-cards-require-kyc","Do stablecoin cards require KYC? What to expect, what gets checked, and why \"no KYC\" cards fall short","Why stablecoin cards ask for ID even with a permissionless wallet, what KYC and KYB collect, why no-KYC cards fall short, and how to fix a rejection.",{"path":592,"title":593,"description":594},"\u002Fresources\u002Fmore\u002Fdo-you-need-a-banking-license-for-a-neobank","Do you need a banking license to launch a neobank? Four routes compared","Most neobanks launch without a bank charter. Compare the four routes, from own charter to embedded providers, in the US, Brazil, Mexico, and the EU.",{"path":596,"title":597,"description":598},"\u002Fresources\u002Fmore\u002Fgenius-act-timeline-key-dates","GENIUS Act and MiCA timeline: the key dates for stablecoin payment teams","Every GENIUS Act and MiCA date that matters to a stablecoin payment flow, how the US effective date is calculated, and what to finish before each deadline.",{"path":425,"title":600,"description":601},"How to automate KYC and KYB for stablecoin payments","A developer guide to automated KYC and KYB for stablecoin payment flows: how verification runs inside a payment API, step-by-step workflows for individuals and businesses, jurisdiction requirements for the US, EU, UK, Singapore, and Brazil, and what to check before settlement.",{"path":603,"title":604,"description":605},"\u002Fresources\u002Fmore\u002Fhow-to-choose-automated-risk-monitoring-vendor","How to choose an automated risk monitoring vendor for a fintech startup","A buyer's guide to automated risk monitoring vendors for early-stage fintechs: the five criteria that matter (regulatory coverage, integration effort, false-positive rate, pricing model, audit output), the question to ask a vendor on each, a checklist table, and what it costs.",{"path":299,"title":607,"description":608},"How to reduce false positives in transaction monitoring without missing real risk","Cut AML alert noise without losing real cases: a 7-step tuning process, the levers that work, the metrics to watch, and what automation should never close.",{"path":610,"title":611,"description":612},"\u002Fresources\u002Fmore\u002Fhow-to-verify-non-custodial-payment-provider","How to verify a payment provider is really non-custodial: 8 checks you can run yourself","Eight checks that prove whether a blockchain payment provider ever holds your funds: on-chain approvals, stored balances, terms of title, failure tests.",{"path":614,"title":615,"description":616},"\u002Fresources\u002Fmore\u002Fhow-wallet-screening-works-stablecoin-payments","How wallet screening works in stablecoin payments: exposure, risk scores, and frozen addresses","How wallet screening works: OFAC-listed addresses, direct and indirect exposure, risk scores, issuer freezes, and what to do when an address is flagged.",{"path":618,"title":619,"description":620},"\u002Fresources\u002Fmore\u002Fkyc-vs-kyb-vs-kyt","KYC vs KYB vs KYT: what each check covers in blockchain payments","KYC verifies people, KYB verifies businesses and their owners, and KYT watches transactions and wallets. What each covers, when it runs, and who owns it.",{"path":622,"title":623,"description":624},"\u002Fresources\u002Fmore\u002Fstablecoin-payment-licenses-msb-mtl-vasp-emi","MSB vs money transmitter license vs VASP vs EMI: which license does a stablecoin payment flow need?","MSB registration, state money transmitter licenses, VASP, EMI, and PSAV compared: who needs each, what triggers it, and when your provider covers you.",{"path":626,"title":627,"description":628},"\u002Fresources\u002Fmore\u002Fmica-stablecoin-rules-explained","MiCA stablecoin rules explained for payment companies","What MiCA means if your business uses stablecoins in the EU: EMTs vs ARTs, issuer requirements, why USDC is compliant and USDT was delisted, and a practical checklist.",{"path":630,"title":631,"description":632},"\u002Fresources\u002Fmore\u002Fneobank-kyc-kyb-onboarding-flow","Neobank KYC and KYB onboarding: screen order, tiered limits, and fewer drop-offs","How to design neobank KYC and KYB onboarding: screen order, which checks run when, tiered limits, rejections, RFIs, and what to log for audits.",{"path":634,"title":635,"description":636},"\u002Fresources\u002Fmore\u002Fneobank-compliance-checklist-stablecoin-rails","Neobank compliance checklist for stablecoin rails: 20 items, owners, and evidence","A 20-item compliance checklist for neobanks on stablecoin rails: AML program, KYC, sanctions, Travel Rule, records, licensing, and evidence to keep.",{"path":638,"title":639,"description":640},"\u002Fresources\u002Fmore\u002Fongoing-sanctions-screening-how-often-to-rescreen","Ongoing sanctions screening: how often to rescreen and what to screen","How often to rescreen customers against sanctions lists, what to screen beyond names, and a cadence that holds up under OFAC strict liability.",{"path":642,"title":643,"description":644},"\u002Fresources\u002Fmore\u002Fpsav-brazil-explained","PSAV in Brazil: the Central Bank's virtual asset license explained","PSAV is Brazil's authorization for virtual asset service providers, created by BCB Resolutions 519, 520, and 521 under Law 14.478\u002F2022. What it requires and who needs it.",{"path":646,"title":647,"description":648},"\u002Fresources\u002Fmore\u002Freal-time-transaction-monitoring-stablecoin-payments","Real-time transaction monitoring for cross-border stablecoin payments","Why stablecoin cross-border flows need different monitoring than wires: the signals that get scored (wallet address risk, velocity, corridor risk, on\u002Foff-ramp counterparties), real-time vs. batch monitoring, and a worked example of a flagged pattern from alert to decision.",{"path":650,"title":651,"description":652},"\u002Fresources\u002Fmore\u002Fblockchain-payment-provider-red-flags","Red flags when choosing a blockchain payments provider: 10 warning signs and what to ask","Ten warning signs to catch before you sign with a blockchain payments provider, how each shows up in a sales call or sandbox, and the question to ask.",{"path":654,"title":655,"description":656},"\u002Fresources\u002Fmore\u002Fstablecoin-card-and-payout-compliance-map","Stablecoin card and payout compliance map: who owns KYC, KYB, sanctions, and the Travel Rule","A compliance map for programs that run stablecoin cards and payouts together: KYC, KYB, monitoring, sanctions, Travel Rule, and records, split by owner.",{"path":658,"title":659,"description":660},"\u002Fresources\u002Fmore\u002Fstablecoin-card-issuing-compliance","Stablecoin card issuing compliance: KYC, KYB, and regulatory coverage explained","What compliance stablecoin card issuing requires: KYC vs. KYB, who is responsible for what, how rules differ in the US, EU, UK, and Latin America, and ongoing monitoring.",{"path":662,"title":663,"description":664},"\u002Fresources\u002Fmore\u002Fstablecoin-cards-europe-mica","Stablecoin cards in Europe: MiCA, euro stablecoins, and what licensing means for cardholders and card programs","How MiCA applies to stablecoin cards in Europe: who needs authorization, how to check a provider on the ESMA register, euro vs dollar stablecoins, SEPA.",{"path":666,"title":667,"description":668},"\u002Fresources\u002Fmore\u002Fstablecoin-cards-united-states-regulation","Stablecoin cards in the United States: the GENIUS Act, sponsor banks, and Visa USDC settlement","How US stablecoin cards are structured and regulated: sponsor bank, program manager, processor, the GENIUS Act, Visa USDC settlement, FDIC coverage, tax.",{"path":670,"title":671,"description":672},"\u002Fresources\u002Fmore\u002Fstablecoin-off-ramp-limits","Stablecoin off-ramp limits: per-transaction, daily, and monthly caps explained","Why off-ramps cap how much you can convert per transaction, day, and month, how the caps map to KYC and KYB tiers, and the documents that raise them.",{"path":674,"title":675,"description":676},"\u002Fresources\u002Fmore\u002Fstablecoin-regulation-tracker-2026","Stablecoin regulation in 2026: MiCA, the GENIUS Act, Brazil, and Japan","Where stablecoin regulation stands in 2026: MiCA in the EU, the GENIUS Act in the US, Brazil's VASP regime, and Japan's issuer rules, compared for payment businesses.",{"path":678,"title":679,"description":680},"\u002Fresources\u002Fmore\u002Fstablecoin-regulation-uk-singapore-hong-kong","Stablecoin regulation in the UK, Singapore, and Hong Kong: where each regime stands in 2026","UK rules start 25 October 2027, Singapore is consulting on its stablecoin law, and Hong Kong licensed its first issuers in April 2026.",{"path":682,"title":683,"description":684},"\u002Fresources\u002Fmore\u002Fgenius-act-for-businesses","The GENIUS Act explained for businesses that use stablecoins","What the GENIUS Act means if your business sends, receives, or holds stablecoins: who it regulates, the dates that matter, and what to do before 2027.",{"path":686,"title":687,"description":688},"\u002Fresources\u002Fmore\u002Ftravel-rule-workflow-hold-return-reject","The Travel Rule in an automated workflow: what to collect, when to hold, when to return","How to automate Travel Rule compliance for stablecoin transfers: what data to collect, the checks before release, and when to hold, reject, or return.",{"path":690,"title":691,"description":692},"\u002Fresources\u002Fmore\u002Ftransaction-monitoring-red-flags-stablecoin-payments","Transaction monitoring red flags for stablecoin payments: 12 rules to automate","The 12 red flags automated transaction monitoring should catch in stablecoin and cross-border payments, with rule logic, actions, and the data each needs.",{"path":694,"title":695,"description":696},"\u002Fresources\u002Fmore\u002Fverification-of-payee-instant-payments","Verification of payee in instant payments: how rails check the recipient before money moves","How EU Verification of Payee, UK Confirmation of Payee, Pix, SPEI, and US payee name checks confirm the recipient before an instant payment becomes final.",{"path":698,"title":699,"description":700},"\u002Fresources\u002Fmore\u002Fvirtual-account-requirements-kyc-kyb","Virtual account requirements: KYC, KYB, and what the bank reviews before it says yes","What you need to open a virtual account: KYC or KYB, the extra fields and source of funds documents the bank reviews, who owns each step, and timelines.",{"path":702,"title":703,"description":704},"\u002Fresources\u002Fmore\u002Fwhat-are-compliance-agents-in-fintech","What are compliance agents in fintech? How they work and what they do for payments","Compliance agents are autonomous software components that run KYC, KYB, sanctions screening, and transaction monitoring inside a payment flow, then document every decision. How they work, what they do for payments, how they differ from traditional compliance software, and how BlindPay embeds them in its API.",{"path":706,"title":707,"description":708},"\u002Fresources\u002Fmore\u002Fwhat-happens-if-a-stablecoin-payment-provider-fails","What happens to your money if a stablecoin payment provider fails?","Issuer, provider, or bank: who fails decides what you get back. What the GENIUS Act and state law protect, where money sits mid-payment, and a runbook.",{"path":710,"title":711,"description":712},"\u002Fresources\u002Fmore\u002Fwhat-is-kyb","What is KYB? Know Your Business verification explained","KYB verifies a company's legal existence, ownership, and control before it can transact. What it checks, who counts as a beneficial owner, and how it differs from KYC.",{"path":714,"title":715,"description":716},"\u002Fresources\u002Fmore\u002Fwhat-is-a-vasp","What is a VASP? Virtual asset service provider explained","A VASP is any business that exchanges, transfers, or custodies virtual assets like stablecoins for customers. FATF's definition and what it requires in practice.",{"path":718,"title":719,"description":720},"\u002Fresources\u002Fmore\u002Fwhat-is-automated-risk-monitoring-fintech","What is automated risk monitoring in fintech?","A reference explainer on automated risk monitoring for fintechs: the four components (KYC\u002FKYB, transaction monitoring, sanctions and watchlist screening, compliance automation), what each one flags, a manual vs. automated comparison, and what FinCEN, FATF, and OFAC actually require.",{"path":722,"title":723,"description":724},"\u002Fresources\u002Fmore\u002Ftravel-rule-stablecoin-off-ramps","What is the travel rule for stablecoin off-ramps? Thresholds, data, and failed checks","The travel rule makes off-ramps pass sender and receiver data with transfers. Thresholds by country, required data, and what happens when checks fail.",{"path":726,"title":727,"description":728},"\u002Fresources\u002Fmore\u002Fgenius-act-usdt-foreign-stablecoin-issuers","What the GENIUS Act means for USDT and other foreign-issued stablecoins","Can USDT stay available in the US under the GENIUS Act? The foreign issuer path, the 2027 and 2028 deadlines, and what payment companies should ask now.",{"path":730,"title":731,"description":732},"\u002Fresources\u002Fmore\u002Fwhere-neobanks-hold-customer-funds","Where does a neobank hold customer funds? FBO accounts, custodial wallets, and non-custodial flows","Pooled FBO bank accounts, custodial stablecoin wallets, or customer-controlled wallets: who holds the money, who reconciles it, and what fails.",{"path":734,"title":735,"description":736},"\u002Fresources\u002Fmore\u002Fcrypto-on-ramp-compliance-who-owns-what","Who owns compliance when you integrate a crypto on-ramp API? KYC, KYB, KYT, and holds","An on-ramp API splits compliance between the provider and you. Who runs KYC, KYB, KYT, sanctions, and the travel rule, and what stays on your side.",{"path":524,"title":5,"description":481},{"path":261,"title":739,"description":740},"Why do crypto off-ramps ask for source of funds? Documents, triggers, and on-chain proof","Why off-ramps ask where your stablecoins came from, how source of funds differs from source of wealth, what triggers a request, and which documents pass.",1793136751651]