Overview

As a payment company regulated in multiple jurisdictions globally, Aspire has a regulatory obligation to conduct transaction monitoring on all money flows on the Aspire platform.

The purpose of our transaction monitoring controls is to protect Aspire, our clients, and our network partners (other licensed financial institutions we use to process payments) from sanctions evasion, money laundering, and other financial crimes.

Transaction monitoring at Aspire is separated into two main areas:

1. Real-time screening - i.e. before the transaction is completed:

Screening client and counterparty names and transaction details against various checks.
Responding to requests for information (“RFIs”) on individual transactions from our network partners.

Notes:

Sometimes transactions will be held for RFI from our network partner (and sometimes their underlying partner). In these cases, the transactions will not be completed until we have been able to fully address our network partner’s questions.
If we require information from you in order to address our network partner’s questions, we will send you an RFI.
While this RFI is open and the review is ongoing, the transfer will not be processed. However, the funds are safeguarded with licensed financial institutions.

2. Retrospective monitoring - i.e. after transactions have been completed:

Monitoring transactional activity to identify patterns that might require further review.
Responding to requests for information on an entity’s transactional activity from our network partners.

Real-time screening vs. retrospective monitoring

	Real-time screening	Retrospective monitoring
What does our system screen or monitor?	All transactions into and out of the Aspire ecosystem are screened in real-time against various rules.	All transactions into and out of the Aspire ecosystem are monitored retrospectively against various rules.
When does this take place?	This screening happens before an inbound credit is credited to your account or before an outbound payment is submitted to our network partners.	This monitoring happens post-transaction: after inbound credits have been credited to your account or outbound payments have been submitted to our network partners.
What can the outcome be?	Transactions can fail real-time screening vs. our internal rules and create an alert. This means an Analyst needs to review the transaction and the reason(s) for the alert.	Transactional activity may create an alert. This means an Analyst needs to review the transactional activity and the reason(s) for the alert.
How do we review real-time and retrospective alerts?	We aim to resolve alerts internally as much as possible, using the information we obtained from you during onboarding and reviewing your previous transactions. However, in some cases, the real-time and retrospective teams will need to request further information from you via an RFI to resolve an alert. When responding to an RFI, it is always best to provide clear and comprehensive answers to our questions - and as much evidence as possible. This helps our teams resolve alerts as quickly as possible. More information on RFIs is in the FAQs section below.	We aim to resolve alerts internally as much as possible, using the information we obtained from you during onboarding and reviewing your previous transactions. However, in some cases, the real-time and retrospective teams will need to request further information from you via an RFI to resolve an alert. When responding to an RFI, it is always best to provide clear and comprehensive answers to our questions - and as much evidence as possible. This helps our teams resolve alerts as quickly as possible. More information on RFIs is in the FAQs section below.

Frequently Asked Questions

Question	Answer
What are the main questions Aspire needs to get comfortable with when reviewing a transaction that’s alerted for manual review?	Who is the sender? Where does the sender derive their funds from? Where relevant, who are their customers? Who is the recipient? What is the relationship between the sender and the recipient? What is the purpose of the transaction? Is that purpose legitimate, given the relationship between the sender and recipient? Is the transaction in line with the sender/recipient’s transactional history and profile?
What are the main types of information and documentation I could be asked to provide in an RFI?	Proof of identity: e.g. passport, driving license, ID card Proof of address: e.g. utility bill, bank statement, mortgage statement Company registration documents: e.g. registered name, trading name, address Proof of business: e.g. sales invoices, product list/brochure, proof of shipping documentation (i.e. bill of lading, airway bill), business contracts/agreements Other information on the relationship between the sender and the recipient (e.g. how it was formed) Director/shareholder register (signed, dated, on headed paper) and employment history of those directors/shareholders Source of funds: e.g, bank statement, payslips, audited business financials, loan contracts Source of wealth: e.g. Will, Grant of Probate, share sale certificates, asset and income declarations, dividend statements Property purchase/sale agreements (incl. price, location, agent/solicitor details, etc.) Links to sender/recipient online presence (if not easily found from our own searches): e.g. LinkedIn profile, listing on e-commerce platforms
Why might Aspire ask additional questions on an RFI, after I answer the first set of questions?	As much as possible, we try to ask all potential questions in our first RFI email to you - and only request the necessary information and documents. However, once we review the information you provide to answer these first questions, we may identify that the information you’ve provided doesn’t sufficiently answer our questions and/or prompts additional questions (e.g. if a document you’ve provided doesn’t make sense or includes contradictory information). In these cases, we may then need to ask additional questions and/or push for further explanation - to ensure we’re fulfilling our regulatory obligations and operating in line with our own internal and network partner bank requirements. Note: In some cases, our RFIs to you ultimately come from us receiving an RFI from our network partner bank. We do our best to answer our partner’s RFI using the information we obtained from you at onboarding, your previous transactions, and/or your previous RFIs. But there will be cases where we need to pass our partner’s questions through to you - and here, we cannot control the questions our partner asks. We do, however, work closely with our partners to educate them on our clients (i.e. start-ups, VC-backed businesses, SMEs etc.) and expected transactional activity - so our partners ask as focused/relevant questions as possible.
How can I provide documents before I submit a transaction (e.g. high-value transactions)?	You can use the link here to proactively provide information about a high-value transaction you intend to receive. This information will be reviewed by our real-time transaction screening team and kept on file. If the team needs to request further information from you in response to what you have provided, they will contact you. In the future, we also plan to add functionality to the Aspire App so that, when creating a transaction above a certain value, you are prompted to provide some further information to support and evidence that transaction. The guidance you receive in the Aspire App will be tailored to the value of the transaction you’re trying to create. The aim of this functionality is to request as much relevant information from you as possible early on - to make the downstream transaction journey (e.g. our network partner’s review) as smooth as possible.
If I proactively provide documents in advance, does that mean I won’t receive any further requests for information on that transaction?	No. Sending documents in advance doesn’t guarantee that we won’t need to request further information at a later stage. If a transaction alerts for manual review it will be reviewed alongside information obtained at onboarding, your previous transactional behaviour, and any documents you might have provided in advance. But if further information is required, this will be requested.
Do some transactions get escalated?	Yes. Depending on the risk profile of a transaction, it may be escalated to Compliance Management. Our real-time screening team makes every effort to do as thorough a review as possible before escalating. However, Compliance Management reviewing the escalation may ask that the real-time team request further information from you so they can make a decision on the transaction.
What types of transactions or entities are likely to receive greater scrutiny - and may result in an RFI?	Transactions from/to countries that pose a higher potential risk of financial crime Transactions from/to senders/recipients with minimal public web presence See our Acceptable Use Policy here for more information on non-permitted activity
If a transaction is manually rejected, can you tell me why?	This can be a sensitive area, and there is a limit to how much information we can share. We are able to share that the transaction has been rejected because: The sender/recipient is engaging in activity that is outside of our Acceptable Use Policy You have not provided sufficient information for us to understand and get comfortable with the transaction
How can I provide a good response to an RFI?	PDF files only We do not accept: Draft and/or unsigned contracts or agreements Word, Excel, etc. documents Screenshots - e.g. of bank statements, email chains, WhatsApp conversations In general, documents should not be older than 3 months Where we ask you a specific question, please respond with a clear answer in sentence form. Don’t simply attach a PDF file with many pages and expect us to comb through it to find the information we need

Questions? Chat with us by clicking on the messenger icon at the bottom right of the screen once you are logged in.

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