1. Overview
When a payment on the ITAM platform involves goods being exported — physically shipped across an international border — additional compliance requirements apply beyond the standard BSA/AML framework. The export of physical goods is regulated under U.S. federal law regardless of the payment method used. Because PayServices Bank facilitates the financial leg of such transactions, it is required to verify that the payment does not facilitate an unlawful export before the transaction is cleared.
This page explains what information and documentation is required for export-related payments, how PayServices Bank screens those payments, and what happens if a controlled or restricted item or destination is identified.
2. Why export controls apply to payments
U.S. export control law — principally the Export Administration Regulations (EAR), 15 CFR Parts 730–774, enforced by the Bureau of Industry and Security (BIS) within the Department of Commerce — restricts and in some cases prohibits the export of certain goods, software, and technology to specific destinations, end-users, or for specific end-uses. The restrictions are based on the nature of the item, the destination country, the recipient, and the intended use.
A financial institution that processes a payment for an export that violates these restrictions may be implicated in the violation. The Office of Foreign Assets Control (OFAC) and BIS have each imposed civil and criminal penalties on financial institutions that processed payments for controlled exports without adequate diligence. OFAC administers country-based and party-based sanctions; BIS administers item-based and end-use-based restrictions under the EAR. The Department of State’s Directorate of Defense Trade Controls (DDTC) administers controls on defense articles under the International Traffic in Arms Regulations (ITAR), 22 CFR Parts 120–130. All three bodies maintain lists of restricted parties and items that PayServices Bank screens against.
The practical consequence is that for a payment to clear, PayServices Bank must be able to verify not only who is paying and who is receiving, but also what is being exported, to where, and with what authorization — before the payment is released.
3. What we require before a product payment can proceed
For any payment categorized as “Goods and services” where the goods are being exported internationally, the sender must provide the following before the transaction can be initiated:
A digitally created invoice
The invoice must be created directly within the ITAM platform using our invoice tool. Scans, photographs, or images of paper invoices are not accepted. This requirement exists because a digitally created invoice carries verifiable metadata — creation time, software origin, and document integrity — that a scanned document cannot provide. A scanned or photographed invoice cannot be authenticated and does not provide the compliance assurance that a digitally originated document does.
Product classification codes for each line item
Each product on the invoice must be assigned the applicable classification codes. The platform supports entry of the following code types:
- Harmonized System (HS) Code — required for all export product payments. The HS Code is a six-digit (or more) international standard code that identifies the nature of the goods for customs purposes. It is the foundation for determining applicable export restrictions.
- Export Control Classification Number (ECCN) — required where applicable. The ECCN is an alphanumeric code (e.g., 3A001) assigned by BIS that identifies whether an item is subject to EAR licensing requirements. Items not listed on the Commerce Control List are designated EAR99, meaning they are generally low-technology consumer goods that do not require a license in most situations — but EAR99 items may still require a license if they are destined for an embargoed country, a restricted end-user, or a prohibited end-use.
- NAICS Code — North American Industry Classification System code describing the business activity of the sender.
- Other regional classification codes — including SITC, NACE, CPC, NOPEMA, NAEMA, and ANZSIC codes as applicable depending on the destination country and the nature of the goods.
The platform’s invoice tool prompts for the applicable codes at the time of invoice creation based on the destination country selected. You will not be required to provide codes that are not relevant to your specific transaction.
Shipping details where applicable
For shipments that have already been booked or documented, the bill of lading or equivalent shipping document should be attached. Where a valid HS code and shipping documentation are both present, the system cross-verifies the shipment details against customs data to confirm that the item description, quantity, and destination are consistent before clearing the payment.
4. Classification codes
The following is a reference guide to the classification codes used in the ITAM export compliance system.
| Code | Full name | Administered by | Purpose |
|---|---|---|---|
| HS Code | Harmonized System Code | World Customs Organization; applied in domestic law by U.S. Customs and Border Protection | Internationally standardized product classification for customs, tariffs, and export statistics. Required for all export product payments on ITAM. |
| ECCN | Export Control Classification Number | Bureau of Industry and Security (BIS), U.S. Department of Commerce | Identifies items subject to the Export Administration Regulations. Determines whether a BIS export license is required. Items not on the Commerce Control List are designated EAR99. |
| NAICS | North American Industry Classification System | U.S. Census Bureau | Classifies the business activity of the sender. Used as a context check against the nature of the goods being exported. |
| SITC | Standard International Trade Classification | United Nations Statistics Division | International trade statistics classification. Used for cross-border commodity analysis. |
| NACE | Nomenclature of Economic Activities | European Union (Eurostat) | EU industrial activity classification. Relevant for payments involving EU-based parties. |
| ANZSIC | Australian and New Zealand Standard Industrial Classification | Australian Bureau of Statistics / Statistics New Zealand | Industry classification for AU/NZ transactions. |
If you do not know the HS Code or ECCN for your product, the ITAM platform provides lookup tools within the invoice creation interface. For ECCN classification, the authoritative source is the Commerce Control List (CCL), Supplement No. 1 to Part 774 of the EAR, available on the Government Printing Office website. If your item is not listed on the CCL, it is designated EAR99 — you may still be required to enter this designation where prompted.
5. Controlled and restricted items
The following categories of items are subject to heightened scrutiny or automatic holds on the ITAM platform. This list is illustrative, not exhaustive — the applicable restrictions depend on the specific ECCN, the destination country, the recipient, and the stated end-use.
Items requiring a BIS export license
Items on the Commerce Control List with a reason for control other than Anti-Terrorism (AT) only generally require a BIS export license for export to controlled destinations or end-users. If an invoice on ITAM includes an item with an ECCN that requires a license for the stated destination, the transaction will be held pending submission of a valid BIS export license specifically authorizing that product, that destination, and that recipient. The license must be current and must not have been revoked or suspended.
Items subject to ITAR
Defense articles, defense services, and related technical data controlled under the International Traffic in Arms Regulations (ITAR) may not be exported without a license from the Department of State’s Directorate of Defense Trade Controls. Payments for ITAR-controlled items require submission of the applicable DDTC authorization before the payment can proceed. PayServices Bank does not determine ITAR classification — it is the sender’s responsibility to determine whether an item is an ITAR-controlled defense article.
Items destined for embargoed countries
Comprehensive embargoes are in place for certain countries including, at the time of this policy, Cuba, Iran, North Korea, Russia (for certain categories), Syria, and others as designated by OFAC and BIS. Payments for goods destined for embargoed countries, even for items that are otherwise freely exportable, are subject to blocking and reporting requirements. The country-specific restrictions are updated continuously and the ITAM platform screens against current lists.
Dual-use goods
Many commercial products have both civilian and military or weapons-development applications. These “dual-use” items are subject to EAR controls even when the stated end-use is civilian. The compliance system assesses the plausibility of the stated end-use against the known export profile for the product type and destination. A claim to export certain advanced processors to a destination known for weapons development will receive heightened scrutiny regardless of the stated end-use.
Geopolitical and commodity anomalies
Beyond official control lists, PayServices Bank maintains a proprietary intelligence layer that flags transactions where the product type and the claimed origin or destination are inconsistent with known facts. Examples that trigger automatic review include a claim to export grain from an active conflict zone, or to ship petroleum products from a country with no known oil production. These flags are based on commodity mapping by country and region and are updated continuously.
6. How transactions are screened
Export-related payments on ITAM go through a multi-layer screening process before clearance.
Automated pre-transaction screening
As soon as an invoice is submitted, the system screens the recipient against all applicable watchlists, including OFAC’s Specially Designated Nationals (SDN) list, OFAC’s Non-SDN Consolidated Sanctions list, BIS’s Entity List, Denied Persons List, and Unverified List, the Department of State’s DDTC Debarred Parties list, and the watchlists of Australia, the European Union, Israel, and the United Kingdom. These lists are synchronized daily. Screening uses both exact matching and fuzzy logic matching to detect name variants and transliterations.
Product and destination analysis
The HS code and ECCN for each line item are cross-checked against the destination country to determine whether a license is required under the EAR for that specific product-destination combination. The ITAM platform maintains a current mapping of the Commerce Control List and updates it as BIS publishes amendments.
Geopolitical intelligence layer
The transaction is assessed against the proprietary intelligence layer described in Section 5. Anomalies between the claimed product, its origin, the stated destination, and known geopolitical and commodity facts trigger escalation to manual review.
Automated clearance vs. manual review
A transaction is automatically cleared when all of the following are true: the recipient does not appear on any watchlist, the product does not require a license for the stated destination, shipping documentation is consistent with the invoice where provided, and no geopolitical or commodity anomaly is detected. When any of these conditions is not met, the transaction is held and routed to our compliance team for manual review. The richer and more complete the classification data provided, the more likely a transaction is to clear without manual intervention.
7. What happens when a payment is held or declined
When a transaction is held for export compliance review, you will receive an in-app notification explaining the basis for the hold and what, if anything, you can provide to resolve it.
If a license is required
If the product requires a BIS export license or DDTC authorization for the stated destination and recipient, you will be prompted to upload the relevant authorization document. The payment will remain on hold until a valid license is verified. If the license cannot be provided, the transaction will be declined and funds returned.
If the recipient is on a watchlist
If the recipient matches a name on a sanctions or watchlist, the compliance team will assess the specific nature of the restriction. Some sanctions apply only to specific types of transactions or items and do not prohibit all financial activity. Where the specific transaction type is permitted under the applicable sanctions program, the hold may be released. Where the transaction type is prohibited, it will be declined, and reporting obligations under OFAC’s regulations will be fulfilled. You will not be informed of the specific SAR or OFAC report filed, if any, in accordance with applicable confidentiality rules.
If a geopolitical or commodity anomaly is detected
The compliance team will reach out in-app to request additional explanation or documentation. You may be asked to provide evidence that the stated export is consistent with the product type and the destination — for example, an independent inspection certificate, a bill of lading, or documentation of the recipient’s business activity. If the anomaly cannot be resolved, the transaction will be declined.
If the invoice is not digitally created
A scanned or photographed invoice will be rejected outright. The transaction cannot proceed until a digitally created invoice is submitted through the ITAM invoice tool. This is not a discretionary requirement — it applies to all export product payments without exception.
8. Invoice requirements
All invoices for export product payments must be created directly within the ITAM platform. The following requirements apply:
- Digital origin. The invoice must be created using the ITAM invoice tool. Scans, photographs, or PDF uploads of externally created invoices are not accepted for export product payments.
- Line-item classification. Each product line must include a valid HS Code. ECCN and other applicable classification codes must be entered where prompted based on the destination country.
- Amount match. The invoice total must match the payment amount exactly.
- Recipient details. The recipient named on the invoice must match the payment recipient. Discrepancies between the invoice recipient and the payment beneficiary may trigger a hold.
- Shipping details. Where a bill of lading or equivalent shipping document exists at the time of payment, it should be attached to the transaction. Where shipping has not yet been arranged, the HS Code and recipient information alone are used for the initial screen; the transaction may be subject to post-clearance verification against actual shipping records.
9. Common questions
Start with the ITAM platform’s built-in lookup tool in the invoice creation interface. If you still cannot determine the ECCN, check the Commerce Control List (CCL), Supplement No. 1 to Part 774 of the EAR, on the Government Printing Office website. If your product is not listed on the CCL, it is designated EAR99. Enter “EAR99” in the ECCN field where prompted. Note that EAR99 items may still require a license if the destination is embargoed or the recipient is on a restricted party list.
Yes, but the process is typically very fast for standard commercial goods. Most EAR99 items exported to non-embargoed destinations and non-restricted recipients clear automatically once the HS Code is entered and the recipient screening returns clean. The classification requirement is not a judgment about your specific goods — it is the mechanism by which the system can make that determination quickly and accurately for every transaction.
Our screening uses fuzzy logic matching, which means partial name matches and name variants may trigger a review even for a different person. When a transaction is held for a potential watchlist match, the compliance team conducts a deeper review to assess the specific nature of the match. You can assist this process by providing identifying information about your recipient — passport number, business registration number, address — that confirms they are not the restricted party. Most fuzzy-match holds are resolved once the recipient’s distinct identity is confirmed.
A scanned invoice can be altered before or after scanning without detection. It carries no verifiable metadata establishing when it was created, who created it, or whether its contents are authentic. A digitally created invoice generated within ITAM carries a creation timestamp, a software signature, and document integrity metadata that can be verified. For export compliance purposes, where the specific product, quantity, and recipient named on the invoice determine whether the transaction can legally proceed, document authenticity is a compliance requirement, not a preference.
If a hold is placed because an export license is required, you will receive an in-app notification with a file upload prompt. Upload a copy of the current, valid BIS export license or DDTC authorization. The license must specifically authorize the product, the destination country, and the recipient named in your transaction. Licenses issued for different products, destinations, or end-users cannot be used. If you anticipate needing to submit a license, you may attach it to the invoice proactively when creating the transaction.
The HS code and invoice requirements described in this policy apply specifically to payments for physical goods being exported. Software and technology transfers may also be subject to EAR or ITAR controls depending on their nature, but the classification code workflow is designed for tangible goods. Payments for controlled software or technical data — including encryption software, software with military applications, or controlled technical drawings — are subject to the same recipient screening and sanctions analysis as all transactions. If you are making a payment for software or technology that you believe may be subject to EAR or ITAR controls, contact us before initiating the transaction.
10. Contact us
For questions about a specific transaction, product classification, or export license submission, contact us through the in-app messaging feature (Account → Help → Compliance question) or by email before initiating the transaction:
PayServices Bank — Compliance
950 W Bannock Street, Suite 1100
Boise, Idaho 83702-6140
United States
info@payservices.com
Related policies: Terms of Service · Source of Funds · Customer Identification Program · Beneficial Ownership Disclosure
1. Overview
When a payment on the ITAM platform involves goods being exported — physically shipped across an international border — additional compliance requirements apply beyond the standard BSA/AML framework. The export of physical goods is regulated under U.S. federal law regardless of the payment method used. Because PayServices Bank facilitates the financial leg of such transactions, it is required to verify that the payment does not facilitate an unlawful export before the transaction is cleared.
This page explains what information and documentation is required for export-related payments, how PayServices Bank screens those payments, and what happens if a controlled or restricted item or destination is identified.
2. Why export controls apply to payments
U.S. export control law — principally the Export Administration Regulations (EAR), 15 CFR Parts 730–774, enforced by the Bureau of Industry and Security (BIS) within the Department of Commerce — restricts and in some cases prohibits the export of certain goods, software, and technology to specific destinations, end-users, or for specific end-uses. The restrictions are based on the nature of the item, the destination country, the recipient, and the intended use.
A financial institution that processes a payment for an export that violates these restrictions may be implicated in the violation. The Office of Foreign Assets Control (OFAC) and BIS have each imposed civil and criminal penalties on financial institutions that processed payments for controlled exports without adequate diligence. OFAC administers country-based and party-based sanctions; BIS administers item-based and end-use-based restrictions under the EAR. The Department of State’s Directorate of Defense Trade Controls (DDTC) administers controls on defense articles under the International Traffic in Arms Regulations (ITAR), 22 CFR Parts 120–130. All three bodies maintain lists of restricted parties and items that PayServices Bank screens against.
The practical consequence is that for a payment to clear, PayServices Bank must be able to verify not only who is paying and who is receiving, but also what is being exported, to where, and with what authorization — before the payment is released.
3. What we require before a product payment can proceed
For any payment categorized as “Goods and services” where the goods are being exported internationally, the sender must provide the following before the transaction can be initiated:
A digitally created invoice
The invoice must be created directly within the ITAM platform using our invoice tool. Scans, photographs, or images of paper invoices are not accepted. This requirement exists because a digitally created invoice carries verifiable metadata — creation time, software origin, and document integrity — that a scanned document cannot provide. A scanned or photographed invoice cannot be authenticated and does not provide the compliance assurance that a digitally originated document does.
Product classification codes for each line item
Each product on the invoice must be assigned the applicable classification codes. The platform supports entry of the following code types:
- Harmonized System (HS) Code — required for all export product payments. The HS Code is a six-digit (or more) international standard code that identifies the nature of the goods for customs purposes. It is the foundation for determining applicable export restrictions.
- Export Control Classification Number (ECCN) — required where applicable. The ECCN is an alphanumeric code (e.g., 3A001) assigned by BIS that identifies whether an item is subject to EAR licensing requirements. Items not listed on the Commerce Control List are designated EAR99, meaning they are generally low-technology consumer goods that do not require a license in most situations — but EAR99 items may still require a license if they are destined for an embargoed country, a restricted end-user, or a prohibited end-use.
- NAICS Code — North American Industry Classification System code describing the business activity of the sender.
- Other regional classification codes — including SITC, NACE, CPC, NOPEMA, NAEMA, and ANZSIC codes as applicable depending on the destination country and the nature of the goods.
The platform’s invoice tool prompts for the applicable codes at the time of invoice creation based on the destination country selected. You will not be required to provide codes that are not relevant to your specific transaction.
Shipping details where applicable
For shipments that have already been booked or documented, the bill of lading or equivalent shipping document should be attached. Where a valid HS code and shipping documentation are both present, the system cross-verifies the shipment details against customs data to confirm that the item description, quantity, and destination are consistent before clearing the payment.
4. Classification codes
The following is a reference guide to the classification codes used in the ITAM export compliance system.
| Code | Full name | Administered by | Purpose |
|---|---|---|---|
| HS Code | Harmonized System Code | World Customs Organization; applied in domestic law by U.S. Customs and Border Protection | Internationally standardized product classification for customs, tariffs, and export statistics. Required for all export product payments on ITAM. |
| ECCN | Export Control Classification Number | Bureau of Industry and Security (BIS), U.S. Department of Commerce | Identifies items subject to the Export Administration Regulations. Determines whether a BIS export license is required. Items not on the Commerce Control List are designated EAR99. |
| NAICS | North American Industry Classification System | U.S. Census Bureau | Classifies the business activity of the sender. Used as a context check against the nature of the goods being exported. |
| SITC | Standard International Trade Classification | United Nations Statistics Division | International trade statistics classification. Used for cross-border commodity analysis. |
| NACE | Nomenclature of Economic Activities | European Union (Eurostat) | EU industrial activity classification. Relevant for payments involving EU-based parties. |
| ANZSIC | Australian and New Zealand Standard Industrial Classification | Australian Bureau of Statistics / Statistics New Zealand | Industry classification for AU/NZ transactions. |
If you do not know the HS Code or ECCN for your product, the ITAM platform provides lookup tools within the invoice creation interface. For ECCN classification, the authoritative source is the Commerce Control List (CCL), Supplement No. 1 to Part 774 of the EAR, available on the Government Printing Office website. If your item is not listed on the CCL, it is designated EAR99 — you may still be required to enter this designation where prompted.
5. Controlled and restricted items
The following categories of items are subject to heightened scrutiny or automatic holds on the ITAM platform. This list is illustrative, not exhaustive — the applicable restrictions depend on the specific ECCN, the destination country, the recipient, and the stated end-use.
Items requiring a BIS export license
Items on the Commerce Control List with a reason for control other than Anti-Terrorism (AT) only generally require a BIS export license for export to controlled destinations or end-users. If an invoice on ITAM includes an item with an ECCN that requires a license for the stated destination, the transaction will be held pending submission of a valid BIS export license specifically authorizing that product, that destination, and that recipient. The license must be current and must not have been revoked or suspended.
Items subject to ITAR
Defense articles, defense services, and related technical data controlled under the International Traffic in Arms Regulations (ITAR) may not be exported without a license from the Department of State’s Directorate of Defense Trade Controls. Payments for ITAR-controlled items require submission of the applicable DDTC authorization before the payment can proceed. PayServices Bank does not determine ITAR classification — it is the sender’s responsibility to determine whether an item is an ITAR-controlled defense article.
Items destined for embargoed countries
Comprehensive embargoes are in place for certain countries including, at the time of this policy, Cuba, Iran, North Korea, Russia (for certain categories), Syria, and others as designated by OFAC and BIS. Payments for goods destined for embargoed countries, even for items that are otherwise freely exportable, are subject to blocking and reporting requirements. The country-specific restrictions are updated continuously and the ITAM platform screens against current lists.
Dual-use goods
Many commercial products have both civilian and military or weapons-development applications. These “dual-use” items are subject to EAR controls even when the stated end-use is civilian. The compliance system assesses the plausibility of the stated end-use against the known export profile for the product type and destination. A claim to export certain advanced processors to a destination known for weapons development will receive heightened scrutiny regardless of the stated end-use.
Geopolitical and commodity anomalies
Beyond official control lists, PayServices Bank maintains a proprietary intelligence layer that flags transactions where the product type and the claimed origin or destination are inconsistent with known facts. Examples that trigger automatic review include a claim to export grain from an active conflict zone, or to ship petroleum products from a country with no known oil production. These flags are based on commodity mapping by country and region and are updated continuously.
6. How transactions are screened
Export-related payments on ITAM go through a multi-layer screening process before clearance.
Automated pre-transaction screening
As soon as an invoice is submitted, the system screens the recipient against all applicable watchlists, including OFAC’s Specially Designated Nationals (SDN) list, OFAC’s Non-SDN Consolidated Sanctions list, BIS’s Entity List, Denied Persons List, and Unverified List, the Department of State’s DDTC Debarred Parties list, and the watchlists of Australia, the European Union, Israel, and the United Kingdom. These lists are synchronized daily. Screening uses both exact matching and fuzzy logic matching to detect name variants and transliterations.
Product and destination analysis
The HS code and ECCN for each line item are cross-checked against the destination country to determine whether a license is required under the EAR for that specific product-destination combination. The ITAM platform maintains a current mapping of the Commerce Control List and updates it as BIS publishes amendments.
Geopolitical intelligence layer
The transaction is assessed against the proprietary intelligence layer described in Section 5. Anomalies between the claimed product, its origin, the stated destination, and known geopolitical and commodity facts trigger escalation to manual review.
Automated clearance vs. manual review
A transaction is automatically cleared when all of the following are true: the recipient does not appear on any watchlist, the product does not require a license for the stated destination, shipping documentation is consistent with the invoice where provided, and no geopolitical or commodity anomaly is detected. When any of these conditions is not met, the transaction is held and routed to our compliance team for manual review. The richer and more complete the classification data provided, the more likely a transaction is to clear without manual intervention.
7. What happens when a payment is held or declined
When a transaction is held for export compliance review, you will receive an in-app notification explaining the basis for the hold and what, if anything, you can provide to resolve it.
If a license is required
If the product requires a BIS export license or DDTC authorization for the stated destination and recipient, you will be prompted to upload the relevant authorization document. The payment will remain on hold until a valid license is verified. If the license cannot be provided, the transaction will be declined and funds returned.
If the recipient is on a watchlist
If the recipient matches a name on a sanctions or watchlist, the compliance team will assess the specific nature of the restriction. Some sanctions apply only to specific types of transactions or items and do not prohibit all financial activity. Where the specific transaction type is permitted under the applicable sanctions program, the hold may be released. Where the transaction type is prohibited, it will be declined, and reporting obligations under OFAC’s regulations will be fulfilled. You will not be informed of the specific SAR or OFAC report filed, if any, in accordance with applicable confidentiality rules.
If a geopolitical or commodity anomaly is detected
The compliance team will reach out in-app to request additional explanation or documentation. You may be asked to provide evidence that the stated export is consistent with the product type and the destination — for example, an independent inspection certificate, a bill of lading, or documentation of the recipient’s business activity. If the anomaly cannot be resolved, the transaction will be declined.
If the invoice is not digitally created
A scanned or photographed invoice will be rejected outright. The transaction cannot proceed until a digitally created invoice is submitted through the ITAM invoice tool. This is not a discretionary requirement — it applies to all export product payments without exception.
8. Invoice requirements
All invoices for export product payments must be created directly within the ITAM platform. The following requirements apply:
- Digital origin. The invoice must be created using the ITAM invoice tool. Scans, photographs, or PDF uploads of externally created invoices are not accepted for export product payments.
- Line-item classification. Each product line must include a valid HS Code. ECCN and other applicable classification codes must be entered where prompted based on the destination country.
- Amount match. The invoice total must match the payment amount exactly.
- Recipient details. The recipient named on the invoice must match the payment recipient. Discrepancies between the invoice recipient and the payment beneficiary may trigger a hold.
- Shipping details. Where a bill of lading or equivalent shipping document exists at the time of payment, it should be attached to the transaction. Where shipping has not yet been arranged, the HS Code and recipient information alone are used for the initial screen; the transaction may be subject to post-clearance verification against actual shipping records.
9. Common questions
Start with the ITAM platform’s built-in lookup tool in the invoice creation interface. If you still cannot determine the ECCN, check the Commerce Control List (CCL), Supplement No. 1 to Part 774 of the EAR, on the Government Printing Office website. If your product is not listed on the CCL, it is designated EAR99. Enter “EAR99” in the ECCN field where prompted. Note that EAR99 items may still require a license if the destination is embargoed or the recipient is on a restricted party list.
Yes, but the process is typically very fast for standard commercial goods. Most EAR99 items exported to non-embargoed destinations and non-restricted recipients clear automatically once the HS Code is entered and the recipient screening returns clean. The classification requirement is not a judgment about your specific goods — it is the mechanism by which the system can make that determination quickly and accurately for every transaction.
Our screening uses fuzzy logic matching, which means partial name matches and name variants may trigger a review even for a different person. When a transaction is held for a potential watchlist match, the compliance team conducts a deeper review to assess the specific nature of the match. You can assist this process by providing identifying information about your recipient — passport number, business registration number, address — that confirms they are not the restricted party. Most fuzzy-match holds are resolved once the recipient’s distinct identity is confirmed.
A scanned invoice can be altered before or after scanning without detection. It carries no verifiable metadata establishing when it was created, who created it, or whether its contents are authentic. A digitally created invoice generated within ITAM carries a creation timestamp, a software signature, and document integrity metadata that can be verified. For export compliance purposes, where the specific product, quantity, and recipient named on the invoice determine whether the transaction can legally proceed, document authenticity is a compliance requirement, not a preference.
If a hold is placed because an export license is required, you will receive an in-app notification with a file upload prompt. Upload a copy of the current, valid BIS export license or DDTC authorization. The license must specifically authorize the product, the destination country, and the recipient named in your transaction. Licenses issued for different products, destinations, or end-users cannot be used. If you anticipate needing to submit a license, you may attach it to the invoice proactively when creating the transaction.
The HS code and invoice requirements described in this policy apply specifically to payments for physical goods being exported. Software and technology transfers may also be subject to EAR or ITAR controls depending on their nature, but the classification code workflow is designed for tangible goods. Payments for controlled software or technical data — including encryption software, software with military applications, or controlled technical drawings — are subject to the same recipient screening and sanctions analysis as all transactions. If you are making a payment for software or technology that you believe may be subject to EAR or ITAR controls, contact us before initiating the transaction.
10. Contact us
For questions about a specific transaction, product classification, or export license submission, contact us through the in-app messaging feature (Account → Help → Compliance question) or by email before initiating the transaction:
PayServices Bank — Compliance
950 W Bannock Street, Suite 1100
Boise, Idaho 83702-6140
United States
info@payservices.com
Related policies: Terms of Service · Source of Funds · Customer Identification Program · Beneficial Ownership Disclosure