Business Flows
Transaction Monitoring is the processing of transactions against a series of rules to look for suspicious or fraudulent activity. The Payment Receiver Router [linked to Mambu Payment Gateway]
process is automatically triggered when an Incoming
or Outgoing
transaction is initiated from Mambu or other system and reaches the Single Euro Payments Area (SEPA) Payment Gateway.
The purpose of Payment Receiver Router [linked to Mambu Payment Gateway]
main process is to decide if the transaction received is a Credit Transfer
or a Direct Debit
. If the payment direction (Incoming
or Outgoing
) received is invalid then the error message is stored in Error Handling -[TM]
State Diagram. For bulk payments, each transaction is sequentially processed and the Anti-Money Laundering (AML) status is received and individually sent back to the SEPA Payment Gateway.
Once the transaction details are read and processed in the MPO process Submit transaction [to ComplyAdvantage and Payment Gateway]
the transaction details are sent to ComplyAdvantage, which sends back the results for the rules configured in the ComplyAdvantage environment. Depending on the alert types received, the AML status of either Accepted
or Suspended
is sent back to the SEPA Payment Gateway.
The diagram below depicts the four business flows covered: Incoming
(Credit Transfer
or Direct Debit
) and Outgoing
(Credit Transfer
or Direct Debit
).
1. Outgoing payment
Outgoing payment
Credit Transfer
When an outgoing payment reaches the SEPA Payment Gateway, a Withdrawal
transaction is automatically posted in Mambu. The SEPA Payment Gateway also triggers the MPO process Payment Receiver Router [linked to Mambu Payment Gateway]
. After the transaction is posted and monitored in ComplyAdvantage, based on the alert status, the AML status can be: Accepted
or Suspended
. This status is sent back to the SEPA Payment Gateway:
Accepted
: the status is updated accordingly in the SEPA Payment Gateway.Suspended
: once all the alerts are transitioned fromIn Review
to an end state ofAccepted
orRejected
, webhooks are sent by ComplyAdvantage that automatically trigger the MPO processAlerts Analyser Router [to be linked to CA]
. The AML status is updated in the SEPA Payment Gateway, which handles the settlement. If the payment isRejected
, aDeposit
transaction is posted in Mambu - by the SEPA Payment Gateway - in the debtor’s account.
Direct Debit
When an outgoing payment reaches the SEPA Payment Gateway, the Payment Receiver Router [linked to Mambu Payment Gateway]
process is automatically triggered. After the transaction is posted and monitored in ComplyAdvantage, based on the alert status, the AML status can be: Accepted
or Suspended
. This status is sent back to the SEPA Payment Gateway:
Accepted
: aDeposit
transaction is posted in Mambu.Suspended
: once all the alerts are transitioned fromIn Review
to an end state ofAccepted
orRejected
, webhooks are sent by ComplyAdvantage that automatically trigger the MPO processAlerts Analyser Router [to be linked to CA]
. The AML status is updated in the SEPA Payment Gateway, which handles the settlement. If the payment isAccepted
, aDeposit
transaction is posted in Mambu and if it’sRejected
there is no transaction posted in Mambu.
2. Incoming payment
Incoming payment
Credit Transfer
When an incoming payment reaches the SEPA Payment Gateway, the Payment Receiver Router [linked to Mambu Payment Gateway]
process is automatically triggered. After the transaction is posted and monitored in ComplyAdvantage, based on the alert status, the AML status can be: Accepted
or Suspended
. When the payment is:
Accepted
: aDeposit
transaction is posted in Mambu.Suspended
: once all the alerts are transitioned fromIn Review
to an end stateAccepted
orRejected
, webhooks are sent by ComplyAdvantage that automatically trigger the MPO processAlerts Analyser Router [to be linked to CA]
. If the payment isAccepted
aDeposit
transaction is posted in Mambu and if it’sRejected
there is no transaction posted in Mambu.
Direct Debit
When an incoming payment reaches the SEPA Payment Gateway, the Payment Receiver Router [linked to Mambu Payment Gateway]
process is automatically triggered. After the transaction is posted and monitored in ComplyAdvantage, based on the alert status, the AML status can be: Accepted
or Suspended
. When the payment is:
Accepted
: aWithdrawal
transaction is posted in Mambu.Suspended
: once all the alerts are transitioned fromIn Review
to an end stateAccepted
orRejected
webhooks are sent by ComplyAdvantage that automatically trigger the MPO processAlerts Analyser Router [to be linked to CA]
. If the payment isAccepted
aWithdrawal
transaction is posted in Mambu and if it’sRejected
there is no transaction posted in Mambu.
3. Alerts logic
No Alerts
If after a transaction is submitted and analyzed by ComplyAdvantage and no alerts are flagged based on the configured rules, the payment AML status is automatically changed to Accepted
since no rule was violated.
Flagged Alerts
Each defined rule generates a pass
or fail
response, with the failed responses creating an alert. Therefore a singular transaction can contain one or more alerts. Each alert on a transaction should be analyzed, investigated and processed through a series of customer-defined workflow states: In Review
, Escalated
, Accepted
etc. Alert states can either be ‘end states’ or not and an alert is considered to be closed when it is moved to an end state such as Accepted
or Rejected
.
Transactions have a priority
action, which is the overall action for the transaction and is derived from the actions of all of the open alerts that a transaction has - such as Soft Stop
or Hard Stop
. Each time the priority action for a transaction changes in ComplyAdvantage (meaning that all alerts with the highest priority that remained unreviewed have been transitioned from In Review
to an end state of Accepted
or Rejected
), a webhook is sent by ComplyAdvantage that automatically triggers the MPO process Alerts Analyser [to be linked to CA]
. The final webhook received for a transaction is the priority
action null (all alerts are in end state
).
Only Soft Stop
If a transaction triggers only Soft Stop
alerts, then based on the value of ignoreSoftStopAlert
field (true
or false
) the payment can be Suspended
or Accepted
in Gateway. Once all the alerts have been transitioned from In Review
to an end state of Accepted
or Rejected
, a webhook is sent by ComplyAdvantage that automatically triggers the MPO process Alerts Analyser [to be linked to CA]
.
Only Hard Stop
If a transaction triggers only Hard Stop
alerts then the payment is Suspended
in Gateway until all the alerts are reviewed. Once all the alerts have been transitioned from In Review
to an end state of Accepted
or Rejected
, a webhook is sent by ComplyAdvantage that automatically triggers the MPO process Alerts Analyser [to be linked to CA]
.
Hard Stop and Soft Stop
If a transaction triggers Hard Stop
and Soft Stop
alerts then the payment is Suspended
in Gateway. If ignoreSoftStop = true
in config, then the final status will be updated in Mambu Payment Gateway after all the Hard Stop alerts are reviewed. If ignoreSoftStop = false
in config, then the final status will be updated in Mambu Payment Gateway only after both Hard Stop alerts and Soft Stop alerts are reviewed, with one exception: after all Hard Stop alerts are reviewed and at least one Hard Stop alert is accepted, the payment is rejected in Payment Gateway without needing to review the remaining Soft Stop alerts.
A notification is sent when conflicting statuses - such as Accepted
and Rejected
- are set for the Soft Stop alerts flagged for a transaction with the following content:
Task was created due to: Conflictual Soft Stop alert states for [Incoming] Transaction message identification [A19Z8EM9F48DSE4MUZ1HRINEJ54QID] and Transaction Id [1QNEQ8LE95D63OA4HX]. Transaction was submitted in ComplyAdvantage but remain [Suspended] in Mambu Payment Gateway. Potential action: Change manually the AML status of the transaction using endpoint [POST /payments/aml] for
Credit Transfer
or [POST /collections/aml] forDirect Debit
.
Notes:
Rejected Outgoing
payments are not stored in Gateway and they are not analyzed by the connector.- In ComplyAdvantage UI, when multiple transactions have the same alerts flagged, at least one of the transactions is reviewed and all the alerts are in an end state (
Accepted
orRejected
) then the alerts end state is inherited by all the other transactions.