Compliance · Why a payment or instrument can pause

What Happens During a Sanctions / Compliance Hold

A non-legalistic view of the operational steps when screening raises a question.

1
Alert generated

A name, country, vessel, bank, goods description or other data triggers a screening/risk alert.

2
Payment/transaction paused

Operations may stop release while compliance determines whether the alert is a false positive or real restriction.

3
Information requested

Bank may ask for ownership, identity, invoice, contract, vessel, goods, licence/end-user or source-of-funds information.

4
Escalation

Compliance/legal/sanctions specialists review the facts and applicable restrictions.

5
Decision

Transaction may be released, rejected, blocked/frozen where law requires, or returned/closed depending on circumstances.

6
Record and future controls

Bank records the decision and may update customer risk, screening data or future transaction requirements.

What can change from bank to bank?

The commercial objective may be similar while the bank’s internal route differs. Credit approval, collateral, compliance review, legal wording, message choice, fees and cut-off times can all vary. Always distinguish those bank-specific steps from the incorporated rules and the purpose of the SWIFT message.

Reviewed: September 2026Standards and bank policy can change.How MyGreed classifies proceduresOfficial-source directory
Procedure ruleThis is a typical learning flow. Exact sequencing, messages, approvals and documents can vary by bank, rules, law and negotiated transaction.