Why Tide Can’t Always Explain a Restriction: “Tipping Off” and Communication Limits

Not necessarily. Limited explanation is often about what can safely be said, not a conclusion about conduct. When a firm is operating financial-crime controls, a detailed “why” can disclose internal detection logic or imply the existence of a report or investigative context, which can be sensitive.

It’s also common for firms to use consistent language across multiple review types. A “routine” eligibility refresh and a higher-sensitivity escalation can share similar outward-facing messaging, because tailoring the wording too precisely can itself reveal what’s happening behind the scenes.

“Tipping off” is the risk of telling someone, directly or indirectly, that they’re suspected of money laundering (or related activity), that a disclosure/report has been made, or that an investigation is contemplated or underway – when that information could affect behaviour and prejudice enquiries.

In practice, “tipping off” can happen through implication as much as through explicit statements. Even a well-intentioned explanation like “your account is paused because we reported X” can be problematic if it signals that the subject is being looked at and changes how they act.

• “Tipping off” is commonly associated with disclosing that a disclosure/report has been made, or that an investigation is contemplated or underway, in circumstances that can prejudice enquiries.
• “Prejudicing an investigation” is broader: it can cover disclosures likely to prejudice an investigation and can also cover mishandling or destroying documents relevant to that investigation.

From a customer’s perspective, both concepts point to the same operational outcome: firms may restrict details about what they are checking, why they are checking it, and what information they hold, until the matter is resolved.

A lack of detail does not prove that a report has been filed. Firms can choose cautious communication even for routine checks, and they may have multiple reasons for restricting the granularity of explanations (including consistency, safety, and internal policy).

Equally, even if a firm has made a report in some scenarios, it typically cannot confirm that to the subject. So “could be” is not a useful inference: the observable behaviour (limited explanation) does not reliably distinguish between routine and higher-sensitivity cases.

In many cases, the practical updates are procedural: what information is required, where it should be provided, whether it has been received, and what happens when the review completes. Tide’s own description of review flow emphasises document requests and final outcome messaging, rather than mid-review commentary.

Where the review touches higher-sensitivity controls, updates can become even more procedural (“we’re reviewing”, “we’ll update you when complete”). That can feel unsatisfactory, but it aligns with the general principle that firms avoid statements that could indirectly reveal suspicion or investigative context.

Monitoring is risk-based and contextual. The same activity can be “expected” for one business profile and “unexpected” for another depending on what was stated at onboarding, what has changed since, and how consistent the pattern is over time.

There is also an escalation element: the first time a pattern appears, it may trigger additional questions; later, if the pattern becomes “normalised” with supporting evidence, it may attract fewer questions – until something else changes (new counterparties, new geographies, different volumes, or changed ownership information).

Requests repeat because:

• Information goes out of date
• Firms have to show they understand ongoing activity, not just activity at a single point in time 

A contract or invoice set from last year may not explain this month’s counterparties or volumes.

Repeated requests can also occur when a firm needs a clearer linkage between money-in and money-out.

For example, a sales invoice may explain incoming funds but not why funds are being forwarded to a particular supplier, or why there are multiple intermediary accounts in the flow.

Sometimes a firm can identify an operational issue (for example, “we need more information about X payment”) without creating a tipping-off risk.

But where the trigger is tied to detection logic, suspicion, or investigative sensitivity, naming the exact transaction can effectively disclose what the monitoring system “noticed”.

This is one reason firms often ask for broader context (“explain these counterparties” or “provide contracts for this line of trade”) rather than saying “transaction ABC is the problem”. The broader request avoids pinpointing the exact detection trigger.

Complaints processes can look at fairness and process, but they cannot override criminal-law constraints around tipping off or prejudicing investigations. In other words, even if a firm would like to be more transparent, it may still be constrained in what it can disclose.

This can produce a frustrating dynamic where the complainant wants a precise narrative reason, but the firm can only speak to procedural points (what was requested, what was received, what decision was made, and what the terms allow). The practical “remedy space” can therefore be narrower than people expect.

Outcomes typically cluster into:

• Continuation (sometimes with conditions)
• Continued restriction pending further information, or closure

The end state often depends on whether the firm can reconcile the account’s observed activity with the business profile and the evidence provided.

Outcomes also differ because “risk” is not only about one transaction. Firms consider patterns, counterparties, sector exposure, and whether the account use remains consistent with eligibility and terms.

Two businesses can supply documents of similar volume, yet one set may clearly explain the commercial rationale while another leaves material gaps.