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 from In Review to an end state of Accepted or Rejected, webhooks are sent by ComplyAdvantage that automatically trigger the MPO process Alerts Analyser Router [to be linked to CA]. The AML status is updated in the SEPA Payment Gateway, which handles the settlement. If the payment is Rejected, a Deposit 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: a Deposit transaction is posted in Mambu.
• Suspended: once all the alerts are transitioned from In Review to an end state of Accepted or Rejected, webhooks are sent by ComplyAdvantage that automatically trigger the MPO process Alerts Analyser Router [to be linked to CA]. The AML status is updated in the SEPA Payment Gateway, which handles the settlement. If the payment is Accepted, a Deposit transaction is posted in Mambu and if it’s Rejected 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: a Deposit transaction is posted in Mambu.
• Suspended: once all the alerts are transitioned from In Review to an end state Accepted or Rejected, webhooks are sent by ComplyAdvantage that automatically trigger the MPO process Alerts Analyser Router [to be linked to CA]. If the payment is Accepted a Deposit transaction is posted in Mambu and if it’s Rejected 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: a Withdrawal transaction is posted in Mambu.
• Suspended: once all the alerts are transitioned from In Review to an end state Accepted or Rejected webhooks are sent by ComplyAdvantage that automatically trigger the MPO process Alerts Analyser Router [to be linked to CA]. If the payment is Accepted a Withdrawal transaction is posted in Mambu and if it’s Rejected 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] for Direct Debit.