Our investigation

Banks should clearly communicate any restrictions they place on accepting international money transfers. They are required to comply with the Anti-Money Laundering and Countering Financing of Terrorism Act 2009, as well as with relevant international sanctions. Banks’ sanctions policies must comply with these obligations, although there is nothing preventing banks from having sanctions policies that are more stringent than the sanctions themselves. Again, however, they should communicate their policies clearly to customers.

In reviewing the bank’s terms and conditions, we could find nothing saying it could decline an incoming international money transfer. As well as failing to communicate this fact, the bank had also not made customers aware of its sanctions policy. There was no mention of the sanctions policy in its terms and conditions or in its instructions for receiving international money transfers. There was a mention of the policy on its website, but it was hard to find.

We reviewed the bank’s calls and emails to Karim and found some to be inaccurate. We also found the tone and content of an email sent to Karim during the bank’s internal complaint-handling process to be inappropriate because it implied Karim had an understanding of sanctions because he was Iranian.

We also reviewed the bank’s email correspondence and messaging via the international SWIFT payment system and found the bank did not proceed with three of the transfers because the recipients failed to respond to its queries by the required deadline, and that the fourth transfer failed because of an error by the recipient.

The bank acknowledged its communications, including its terms and conditions, were inadequate and undertook to make explicit mention in its terms and conditions that it would not always accept international money transfers.

Finally, the bank gave us information in confidence showing its actions were not based on Karim’s Iranian nationality. 

Outcome

The bank offered Karim $1,500 compensation for the stress and inconvenience he had suffered. He accepted the offer.