By: Money Navigator Research Team
Last Reviewed: 20/01/2026
FACT CHECKED
Quick Summary
Cross-border transfers are more likely to be queried or delayed because they pass through extra checks (sanctions screening, AML risk controls, and message-quality rules) and often involve intermediaries outside your bank’s direct control.
A “hold” is usually a temporary pause while information is reviewed, but outcomes vary: the payment can be released, returned, cancelled, or escalated into a wider review depending on what the checks find and what information is available.
This article is educational and not financial advice.
What “under review” typically means in practice
When a bank (or payment provider) flags an international transfer, the pause is usually driven by one of three mechanisms:
1) Screening hits (sanctions / watchlists / name matching)
Payments are commonly screened against sanctions and other restriction lists. Even legitimate payments can be delayed by “false positives” (for example, a beneficiary name similar to a listed individual or entity).
UK context matters here because UK financial sanctions are administered through HM Treasury’s Office of Financial Sanctions Implementation (OFSI), and firms need processes that can stop or delay payments when a potential match is identified.
A useful reference point for what UK financial sanctions are and how they operate is the government’s UK financial sanctions general guidance.
2) AML / risk-based controls (transaction doesn’t fit the profile)
International payments can trigger risk controls when the transaction pattern doesn’t align with what the firm expects from the account or customer (value, frequency, destination, counterparty type, or business rationale). UK AML frameworks are built around a “risk-based approach” and monitoring for unusual activity.
For a high-level overview of the risk-based concept and typical due diligence expectations, see Your responsibilities under money laundering supervision.
3) Payment message quality or missing purpose information
Cross-border wires often rely on structured payment messages and specific identifiers. If the purpose of payment, payer/payee details, or supporting narrative is incomplete (or inconsistent), the transfer can be rejected, returned, or pushed into a manual queue.
International standards also influence what “good” payment transparency looks like. FATF’s framework includes payment transparency expectations (commonly referenced in discussions about cross-border payment information standards): The FATF Recommendations.
Why cross-border transfers are more delay-prone than domestic payments
Cross-border payments often include at least one additional link in the chain:
Correspondent banking / intermediaries: A sending bank may route a payment through one or more correspondent banks before it reaches the beneficiary bank. Each participant can apply its own screening and risk controls.
Time zones and cut-offs: Processing windows and compliance queues can run on different schedules across jurisdictions.
Data translation and formatting: Differences in character sets, local address conventions, and beneficiary identifiers can create mismatches that push a payment into exceptions handling.
Common triggers that lead to queries, delays, or holds
Below are the patterns most often associated with “review” statuses on business transfers (without implying wrongdoing):
Counterparty and jurisdiction triggers
New supplier/customer abroad with no prior history on the account
Destination or intermediary in a higher-risk jurisdiction (by the firm’s internal model)
Complex ownership structures or unclear beneficial ownership behind the counterparty
Related reading on ownership changes and reverification: Beneficial ownership (PSC) changes: what triggers bank reverification.
Transaction pattern triggers
Step change in values (e.g., first time sending a much larger amount)
Multiple payments split into smaller amounts with the same counterparty or similar references
Third-party payments (payer and underlying obligor differ from the customer profile)
Narrative and documentation triggers
Vague descriptions (“services”, “consultancy”, “misc”) when the firm expects more specificity
Invoices/contracts that don’t align with the payment narrative (dates, amounts, goods/services)
Unclear source of funds vs source of wealth explanations where requested
For definitions and why firms distinguish the two, see Source of funds vs source of wealth: what banks mean.
Operational edge cases (where the payment status becomes messy)
A payment is in-flight and the account later becomes restricted/closed
Amendments or recalls are attempted mid-route (which can require intermediary cooperation)
This is a common “what happens next?” scenario in: Outgoing payments if an account is closed mid-processing.
Summary table
| Scenario | Outcome | Practical impact |
|---|---|---|
| Name or entity screening “close match” | Payment paused for manual review | Supplier may not be paid on expected date; follow-on fees/penalties may apply under contracts |
| New overseas supplier with limited history | Request for information (RFI) | Finance team time spent producing invoices, contracts, shipping proof, emails |
| Missing/unclear payment purpose | Repair or rejection/return | Payment can bounce back; accounting reconciliation becomes harder |
| Intermediary bank adds its own hold | Delay outside your bank’s direct control | ETA becomes uncertain; tracking may be limited depending on rails/provider |
| Pattern looks inconsistent with normal activity | Escalation to enhanced review | Wider questions about activity may be raised beyond this single payment |
What information is usually requested when a payment is queried?
A query is often a structured request to evidence the purpose and economic rationale of the transaction. Common categories include:
Commercial documents: invoice, purchase order, contract, statement of work
Fulfilment evidence (where relevant): shipping docs, delivery confirmations, customs paperwork
Counterparty verification: company registry extracts, address/website confirmation, ownership disclosures where relevant
Context for funds movement: why this supplier/customer, why this jurisdiction, why now
A broader (still useful) checklist of the kinds of documents firms may request during heightened scrutiny is here: Documents banks ask for when considering account closure. (Even though that article is closure-oriented, many document types overlap with payment-level RFIs.)
For deeper context on when firms apply additional scrutiny to SMEs, see: Enhanced due diligence (EDD) for SMEs: triggers, checks, and outcomes.
Scenario Table
| Scenario-level | Process-level | Outcome-level |
|---|---|---|
| Cross-border payment flagged by rules engine | Queueing into compliance triage; screening and risk scoring reviewed | Released, returned, cancelled, or escalated |
| “Close match” to restricted name/entity | Manual investigation; potential request for additional identifiers | Cleared and released, or blocked/frozen depending on match assessment |
| Missing structured data (beneficiary details/reference) | Payment repair attempt or rejection routing | Delay with repair, or return to sender |
| Intermediary bank intervention | Intermediary applies its own controls; messages exchanged bank-to-bank | Uncertain timelines; limited visibility in some cases |
| Wider risk concerns emerge | Review expands beyond the single transfer | Additional questions; possible broader restriction outcomes |
When banks may give limited detail about the reason for a hold
Some holds occur in contexts where disclosure is constrained (for example, where a report or investigation could be prejudiced). In the regulated sector, UK law includes “tipping off” offences in certain circumstances. The text of the relevant offence provision can be found at Proceeds of Crime Act 2002: section 333A (tipping off – regulated sector).
This does not mean every delayed payment involves suspicion of wrongdoing; it means communications can be limited in some scenarios.
Payment tracking: why “where is my money?” can be hard to answer
Domestic payments often have clearer status visibility than international wires. Some banks offer enhanced tracking for SWIFT-based payments via SWIFT gpi; the product overview is here: Swift GPI.
Where tracking exists, it can help pinpoint whether a payment is:
still with the sending bank,
in an intermediary stage,
with the beneficiary bank awaiting posting/repair.
Compare Business Bank Accounts
Businesses that trade internationally often compare providers on operational features (supported currencies, international transfer rails, tracking visibility, and how RFIs/document uploads are handled) rather than headline pricing alone.
A neutral starting point for comparing UK options is: Business bank accounts.
Frequently Asked Questions
Timelines vary because the review can be completed by your bank, by an intermediary, or by the beneficiary bank, and each party may operate different cut-offs and queues. Some reviews clear quickly when the query is purely data-quality related (for example, missing details that can be corrected).
Where the review relates to screening or risk assessment, additional checks and information requests can extend the timeline. Even after a bank clears its own checks, an intermediary’s controls can still introduce delay.
A queried payment is often transaction-specific: it can be triggered by the counterparty, the jurisdiction, or missing information for that single transfer. Many cases resolve without any broader account impact.
That said, if the information received during the query suggests inconsistencies with the expected profile, a firm may decide to widen the review. That wider step is a risk-management choice, not an automatic consequence of every delayed payment.
Yes. Returns happen for operational reasons (incorrect beneficiary details, account closed, message format issues) and for control reasons (for example, an intermediary cannot process the transfer without resolved queries).
A “return” can create reconciliation complexity because the return may not mirror the original payment reference cleanly, and FX movements or fees can affect the amount that comes back.
Cross-border wires may rely on correspondent banking networks to reach certain destinations or beneficiary banks. Intermediaries can apply their own screening and control standards based on their jurisdiction and risk model.
This is one reason banks sometimes cannot provide a precise ETA: they may not control the intermediary’s compliance queue or repair process.
RFI means “request for information”. It typically asks for clarification on the purpose of payment, the underlying contract/invoice, or the relationship between payer and payee.
RFIs are common when the payment narrative is vague, when the counterparty is new, or when transaction size/frequency differs from historical patterns. The request is often focused on evidencing commercial rationale rather than the mechanics of the payment itself.
Sanctions screening is not limited to a country-level filter. It can involve name and entity matching and considerations about ownership/control, depending on the applicable regime and the firm’s controls.
Because matching is not always straightforward (and false positives occur), payments can be paused for manual review even when the underlying transaction is legitimate.
Sometimes they can explain operational issues (missing information, formatting repairs, beneficiary bank requirements). In other situations, the level of detail can be limited.
UK law includes offences relating to disclosures that could prejudice certain investigations in the regulated sector. This can constrain how a firm communicates in specific scenarios, even if the customer is seeking a simple explanation.
That depends on the contract and the counterparty’s terms. From a practical perspective, delays can affect shipment release, service commencement, or late-fee triggers even when the payer initiated the transfer on time.
From a finance operations standpoint, delays also affect cashflow forecasting and can introduce extra workload: chasing confirmations, providing proof of payment initiation, and reconciling eventual settlement.
Most banks and payment firms have a complaints process. For some complaint types, firms may have shorter response times than the standard eight-week window.
The Financial Ombudsman Service summarises time limits for certain payment services complaints here: Time limits. Eligibility depends on the complainant type and the specific circumstances.
- A hold is a pause while checks or clarifications are completed; the payment may still proceed.
- A rejection typically means the payment could not be processed (often due to missing/invalid information) and may be returned.
- A recall is an attempt to pull the payment back after initiation; success can depend on where the payment is in the chain and whether the beneficiary bank has already credited the funds.
International payments are operationally “thin ice” because they sit at the intersection of multiple control regimes (sanctions, AML risk controls, and payment-message standards) across multiple institutions.
The core hidden mechanism is not one bank “deciding to be difficult”; it’s that a single transfer can be interrupted at several points by different parties, each with independent obligations, tooling, and risk appetite.
The practical implication for SMEs is that certainty can be hardest to obtain precisely when certainty is most valuable (supplier deadlines, stock release, or payroll-adjacent supplier payments).
Designing internal processes that can evidence purpose and counterparty context quickly often matters more than the payment method alone.