Returning funds

Where funds must be returned, the default position is that they will be returned only to the account from which they were received.

Funds must not be redirected to the client, another party or a different account merely because the payer or client requests it. Any proposed exception must be supported by a clear explanation, must be consistent with the underlying legal matter and must be referred to the Accounts Team for approval, with MLRO input where appropriate.

You must remain alert to attempts to use Keystone to receive funds from one source and transmit them to another, thereby creating an artificial audit trail or an additional layer between the funds and their true origin.

Document Upload System