Why we ask
ITAM is a regulated bank account. PayServices Bank is chartered in Idaho under U.S. federal banking law. When we ask about the source of funds on a transaction, we are acting under a specific, mandatory legal obligation — not a general policy preference.
The operative statute is 31 CFR § 1020.320(a)(2)(iii), which requires us to file a Suspicious Activity Report (SAR) whenever a transaction "has no business or apparent lawful purpose or is not the sort in which the particular customer would normally be expected to engage, and the bank knows of no reasonable explanation for the transaction after examining the available facts, including the background and possible purpose of the transaction." Understanding where funds came from is often the only way we can determine whether a reasonable explanation exists.
A source-of-funds request is not an accusation. It is the process by which we gather the "available facts" that the law requires us to examine before we can determine whether a SAR must be filed. We ask only when a specific transaction — or pattern of transactions — triggers that statutory evaluation on your account.
The three-tier monitoring model
Every account opens at Tier 1. Tier assignment reflects the intensity of transaction monitoring applied to the account — it is driven entirely by what happens on the account, not by who the Member is. There is no declared-purpose questionnaire at opening, and tier assignment is never based on nationality, occupation title, or other profile characteristics.
Automated screening for SAR triggers (31 CFR § 1020.320). No documentation requests unless a specific transaction triggers the SAR evaluation process.
One or more transactions have triggered the mandatory SAR evaluation under 31 CFR § 1020.320(a)(2). We are examining available facts, which may include a source-of-funds request, to determine whether a SAR must be filed.
A pattern of transactions across multiple SAR evaluations that cannot be resolved through a single review. Senior compliance staff conduct periodic re-review. Account functionality may be limited if the pattern cannot be resolved.
How your account profile is built
The third SAR trigger in 31 CFR § 1020.320(a)(2)(iii) requires us to evaluate whether a transaction is "not the sort in which the particular customer would normally be expected to engage." To make that evaluation accurately, we need an account-level baseline — a profile of what normal looks like for your specific account. That profile is also required independently by our AML program under 31 CFR § 1020.201(b)(1)(v)(A).
We build that profile from two sources only. We do not ask you to declare your intended use at account opening.
Source 1: Identity verification data from account opening
When you opened your account, we collected your full legal name, date of birth, address, and identification number as required by our Customer Identification Program (CIP) under 31 CFR § 1020.220. The CIP is the mandatory process by which every bank verifies who its customers are before opening an account — it is described in full at customer-identification. That data, together with your account type (personal or business, domestic or international), tells us what category of account this is and establishes what types of transactions are plausible for that category. This is the starting point for your profile.
Source 2: Your actual transaction history
As you use your account, the monitoring system observes the amounts, frequency, counterparties, corridors, and transaction types that characterize your account. This observed history becomes your profile. It is account-specific and it updates continuously — it reflects what you actually do, not what you said you would do. A declared intention at opening could change at any moment and would not be a reliable baseline anyway.
Why this matters for a source-of-funds request
When a transaction deviates materially from your established profile and no apparent lawful explanation is visible from the transaction data alone, the law requires us to examine "the available facts, including the background and possible purpose of the transaction" before deciding whether a SAR must be filed. Asking about the source of funds is how we gather those facts. The request is specific to that transaction — not a general audit of your account.
What moves an account between tiers
Two categories of trigger move an account from Tier 1 to Tier 2: the three mandatory SAR triggers under 31 CFR § 1020.320(a)(2), and sanctions-match events under 31 U.S.C. § 5318(l) and applicable OFAC regulations. No other factor — not a Member's position, nationality, occupation, or transaction volume alone — is a standalone trigger under federal law.
| Statutory trigger | Regulation | What it means in practice |
|---|---|---|
| Funds from illegal activity or designed to conceal them | 31 CFR § 1020.320(a)(2)(i) | The transaction involves funds that appear derived from illegal activities, or is structured to hide or disguise funds or assets from illegal activities — including concealing their ownership, nature, source, location, or control — as part of a plan to violate or evade any federal law or regulation. |
| Designed to evade BSA requirements | 31 CFR § 1020.320(a)(2)(ii) | The transaction appears designed to evade any requirement of 31 CFR Chapter X. This includes structuring — breaking up transactions specifically to avoid any BSA reporting requirement — which is independently prohibited under 31 CFR § 1010.314 regardless of the dollar amount or the type of reporting being evaded. |
| No apparent lawful purpose after examining available facts | 31 CFR § 1020.320(a)(2)(iii) | The transaction has no business or apparent lawful purpose, or is not the sort the customer would normally be expected to engage in, and we know of no reasonable explanation after examining the available facts. This is the trigger most likely to generate a source-of-funds request — gathering those facts is how we determine whether a reasonable explanation exists. |
| Sanctions match — account holder or counterparty | 31 U.S.C. § 5318(l); applicable OFAC regulations | The account holder or a transaction counterparty appears on a sanctions list maintained by OFAC or another authority to which we are subject. Because sanctions regimes are jurisdiction-specific, a match on one list does not necessarily mean every transaction is blocked — only transactions that fall within the scope of the applicable sanctions program are affected. See the note on jurisdiction-specific sanctions below. |
How jurisdiction-specific sanctions work
Sanctions are not uniform. OFAC administers dozens of distinct programs — each tied to a specific country, region, or category of designated persons — and each program defines precisely which transactions it prohibits. A person or entity may be designated under one program but not another, and a transaction may be prohibited under one program while being fully permissible under others.
Our system evaluates every transaction on its specific facts: the identity of the parties, the jurisdiction of the counterparty, the currency corridor, the nature of the transaction, and which sanctions programs apply to each element. If a Member appears on a sanctions list, that does not automatically restrict all of their transactions — it restricts only those transactions that fall within the scope of the program under which they are designated. The Terms of Service describe this transaction-by-transaction evaluation in Section 3 (Sanctions and restricted persons).
When a sanctions match is detected on a specific transaction, that transaction is blocked, rejected, or held for review as required by the applicable program. The account is elevated to Tier 2 for enhanced monitoring of subsequent transactions involving the same parties or corridors. OFAC blocking and rejection reports are filed as required. We may be legally prohibited from telling you the reason a specific transaction was blocked if doing so would reveal the existence of a regulatory filing.
Moving back down — how tier elevation ends
Being in Tier 2 or Tier 3 is not permanent. Federal law at 31 CFR § 1020.201(b)(1)(v)(B) requires us to maintain and update customer information "on a risk basis" — which means tier assignments must be reviewed and revised when the underlying basis for them changes. An account moves back to a lower tier when the condition that caused the elevation is resolved:
- SAR trigger resolved: the SAR evaluation is completed — either a SAR is filed and the pattern does not continue, or a reasonable explanation is confirmed and no SAR is required. Once resolved with no continuing pattern, monitoring returns to Tier 1.
- Sanctions match resolved: the specific transaction was blocked and filed as required, subsequent transactions involving the same parties or corridors show no further matches, and no ongoing pattern of sanctions-adjacent activity is detected. The account returns to Tier 1 monitoring for transactions that are not within the scope of the applicable sanctions program.
- Tier 3 pattern resolved: a sustained period — defined in our written BSA/AML program — passes without new triggers, and senior compliance review confirms the pattern is no longer active. The account steps down to Tier 2 first, then to Tier 1 if the Tier 2 evaluation also closes cleanly.
If your account has been elevated and you believe the underlying basis no longer exists, you can contact us through the in-app compliance channel (Account → Help → Compliance question). We will review the account and explain, to the extent permitted by law, what information we need to close the evaluation.
What we need from you
When a transfer triggers a compliance review, we will specify which payment category applies and what documentation is needed. All transfers are reviewed in the order they were submitted. Any transaction pending secondary review can be cancelled at any time from your end. All funds are held in a non-interest bearing escrow account for the duration of the review and returned immediately if the transaction is reversed.
For faster processing, we recommend using the tools available in ITAM to generate invoices, pay stubs, and structured digital contracts — these are accepted as documentation and help resolve reviews quickly. The in-app request will tell you exactly which category applies to your situation. You will never be asked to provide documentation for every category on this list.
Charitable contributions
Proof that the recipient organization is a registered entity whose primary purpose is philanthropy and social well-being (educational, religious, or other activities serving the public interest). Acceptable documents include:
- A current valid tax exemption certificate;
- A statement from a State taxing body, State Attorney General, or other appropriate State official certifying nonprofit status and that no net earnings accrue to private shareholders or individuals;
- A certified copy of the organization’s certificate of incorporation or similar document clearly establishing nonprofit status; or
- Any of the above for a State or national parent organization, together with a statement signed by the parent confirming the recipient is a local nonprofit affiliate.
Consulting, professional, legal, and advisory fees
Proof that the transfer is payment for consulting, professional, legal, or advisory services. Acceptable documents include an engagement letter, a representation contract, or an invoice.
Commission, royalty, trademark, patent, and copyright fees
Proof that the transfer is payment for commissions, royalties, trademarks, patents, or copyright fees. Acceptable documents include a licensing agreement, a copy of the patent or trademark (if the recipient is not named on the patent or trademark, also include proof of their ownership), an engagement letter, a representation contract, or an invoice.
Dividends and profits
Proof that the transfer is payment for dividends or profits. Acceptable documents include a contract attesting to the payment owed, proof of ownership or sale of securities by the recipient, or an invoice.
Education and tuition
Proof of enrolment in a school or education program offered by the recipient. If the recipient is an agent rather than the institution directly, also include proof of the relationship between the school and the agent.
Equity and commercial investments
A copy of a stock purchase agreement, executed term sheet, investment contract, or other document evidencing the equity or commercial investment. The amount of the transfer must match the payment terms identified in the documents you provide.
Friend or family (money remittance)
For direct family members: a copy of a birth certificate evidencing the relationship between parent and child, adoption papers where applicable, or a marriage licence or certificate. For non-direct family members or friends: proof that you know each other — for example, a photograph where both you and the recipient are clearly present.
Goods and services
An invoice matching the exact amount of the transaction. The documentation must be sufficient for our compliance team to confirm the legitimacy of the transaction and the accuracy of the amount.
Insurance payment
A copy of the insurance policy or contract, together with a payment statement or premium invoice as applicable.
Inter or intra group transfer (treasury)
Proof of the relationship between the two entities. A purely commercial relationship (buyer and seller) does not qualify for this category. Valid relationships include both companies being part of the same group, one company being owned by the other, or both companies being owned by the same shareholders. A substantial common majority shareholder may also be accepted in certain cases. Both the sender and the recipient must be named in the documentation provided.
Licensing fees
A copy of the licensing agreement between the sender and recipient, and/or an invoice as applicable.
Medical bills
A copy of an invoice for medical treatment, a hospital bill, or a payment statement from a clinic for medical services rendered.
Other
Documentation sufficient for our compliance team to confirm the legitimacy of the transaction and the accuracy of the amount. Because this category is a catch-all, the more specific the documentation, the faster the review.
Real estate lease or purchase
A copy of the lease agreement, purchase contract, bill of sale, or invoice as applicable.
Reimbursement
Proof of the original payment for which you are submitting the reimbursement. The documentation must include sufficient detail about the reason and purpose of the original payment. For example, if you are reimbursing an invoice previously paid in full or in part, include a copy of that invoice.
Salary and compensation
A copy of an employment agreement and/or other related bills, agreements, or contracts evidencing payments due as part of your professional engagement.
Settlement (dispute resolution)
A copy of the agreement or communication evidencing the settlement amount and the reason for the settlement.
Taxes and fees
A copy of a tax return, declaration, or statement of payment due to a tax authority or government entity. The payment being submitted must correspond to the documentation provided.
Transfer to own account (withdrawal)
A copy of a bank account statement in your name, or a bank letter confirming that the destination account is owned by you (the sender).
Transportation and travel costs
Proof of payment for transportation and travel-related costs, including lodging. Acceptable documents include a hotel reservation or bill, or proof of payment for airfare.
Utility bills
A copy of the utility bill for which you are submitting the payment.
How to respond to a request
When we need source-of-funds information, you will receive an in-app notification with a clear explanation of what we need and why. The request will specify:
- Which payment category applies (e.g., salary and compensation, goods and services, real estate lease or purchase) and what documentation is required for that category;
- The deadline for responding (typically 14 days for a standard request, 30 days for complex situations);
- The consequence of not responding — usually a temporary hold on outgoing transactions until we receive the information; and
- A link to this page and to the in-app upload tool.
If the documentation category does not match your situation, tap "My situation is different" in the in-app request. This routes you to a compliance agent who can discuss your circumstances and identify the right documentation.
If you need more time, tap "Request an extension". Extensions of up to 14 days are usually granted without requiring a reason.
What happens next
Once you submit documents, a compliance analyst reviews them. In most cases you will receive a decision within two business days. If we have a follow-up question, we will contact you through in-app messaging.
If the review is satisfactory:
- Any temporary hold on outgoing transactions is lifted immediately;
- Your account returns to normal operation; and
- The documented source-of-funds information is stored in your compliance file and you will not be asked again unless your risk profile changes materially.
If we are unable to verify the source of funds to our satisfaction, we will notify you and explain our next steps, which may include a further request for documentation, a limitation on specific transaction types, or — in cases where we cannot resolve the matter — closure of the account with return of your funds.
Common questions
No. A source-of-funds request is a routine compliance step triggered by objective risk criteria — not by suspicion of any specific wrongdoing. The overwhelming majority of Members who receive such requests provide their documentation and continue using their accounts without any issue. Every major bank in the world applies similar procedures.
Being at Tier 2 means a specific transaction on your account has triggered the mandatory SAR evaluation process under 31 CFR § 1020.320(a)(2). The tier is not a judgment about you — it is a description of where your account is in a statutory compliance process that the law requires us to complete.
Once the evaluation is resolved — either because a reasonable explanation is confirmed or because we complete any required SAR filing and the pattern does not continue — the account returns to Tier 1 monitoring. Most Tier 2 accounts resolve quickly once we receive the information we ask for.
We share your documents only as required or permitted by law. This includes responding to valid legal process (court orders, regulatory subpoenas), filing regulatory reports where required (such as Currency Transaction Reports to FinCEN), and — where we participate — voluntary information sharing with other financial institutions under Section 314(b) of the USA PATRIOT Act for AML/CFT purposes.
We do not sell your documents or share them for any commercial purpose. The full details are in our Privacy Notice.
No. Your job title, occupation, or public position is not a trigger under the three statutory SAR criteria (31 CFR § 1020.320(a)(2)). There is no definition of "politically exposed person" in U.S. federal law, and no provision of the Bank Secrecy Act or its implementing regulations requires a bank to screen for or apply special treatment to any person based solely on their political or government position.
A source-of-funds request from ITAM means a specific transaction on your account has triggered the SAR evaluation process. It is always about the transaction, not about who you are.
Tell us. Tap "My situation is different" in the in-app request to reach a compliance agent. We understand that not every situation fits a standard template — for example, if you are self-employed in a country that does not require formal tax returns, or if you received funds from a source that does not generate standard documentation.
Our goal is to understand the economic reality of your situation, not to collect a specific form. We will work with you to find documentation that satisfies our requirements.
U.S. federal law (31 CFR § 1020.220) requires banks to retain records related to customer identification and due diligence for five years after an account is closed. We retain source-of-funds documentation for the same period. After that, records are deleted in accordance with our data-retention schedule.
While your account is open, you can view the documents you have uploaded in the Account → Compliance section of the ITAM app.
Contact us
If you have questions about a source-of-funds request or about your risk tier, please reach us through the in-app messaging feature (Account → Help → Compliance question) or by email:
PayServices Bank — Compliance
950 W Bannock Street, Suite 1100
Boise, Idaho 83702-6140
United States
info@payservices.com
Related policies: Customer Identification Program · Source of Wealth · Beneficial Ownership Disclosure · Privacy Notice
Why we ask
ITAM is a regulated bank account. PayServices Bank is chartered in Idaho under U.S. federal banking law. When we ask about the source of funds on a transaction, we are acting under a specific, mandatory legal obligation — not a general policy preference.
The operative statute is 31 CFR § 1020.320(a)(2)(iii), which requires us to file a Suspicious Activity Report (SAR) whenever a transaction "has no business or apparent lawful purpose or is not the sort in which the particular customer would normally be expected to engage, and the bank knows of no reasonable explanation for the transaction after examining the available facts, including the background and possible purpose of the transaction." Understanding where funds came from is often the only way we can determine whether a reasonable explanation exists.
A source-of-funds request is not an accusation. It is the process by which we gather the "available facts" that the law requires us to examine before we can determine whether a SAR must be filed. We ask only when a specific transaction — or pattern of transactions — triggers that statutory evaluation on your account.
The three-tier monitoring model
Every account opens at Tier 1. Tier assignment reflects the intensity of transaction monitoring applied to the account — it is driven entirely by what happens on the account, not by who the Member is. There is no declared-purpose questionnaire at opening, and tier assignment is never based on nationality, occupation title, or other profile characteristics.
Automated screening for SAR triggers (31 CFR § 1020.320). No documentation requests unless a specific transaction triggers the SAR evaluation process.
One or more transactions have triggered the mandatory SAR evaluation under 31 CFR § 1020.320(a)(2). We are examining available facts, which may include a source-of-funds request, to determine whether a SAR must be filed.
A pattern of transactions across multiple SAR evaluations that cannot be resolved through a single review. Senior compliance staff conduct periodic re-review. Account functionality may be limited if the pattern cannot be resolved.
How your account profile is built
The third SAR trigger in 31 CFR § 1020.320(a)(2)(iii) requires us to evaluate whether a transaction is "not the sort in which the particular customer would normally be expected to engage." To make that evaluation accurately, we need an account-level baseline — a profile of what normal looks like for your specific account. That profile is also required independently by our AML program under 31 CFR § 1020.201(b)(1)(v)(A).
We build that profile from two sources only. We do not ask you to declare your intended use at account opening.
Source 1: Identity verification data from account opening
When you opened your account, we collected your full legal name, date of birth, address, and identification number as required by our Customer Identification Program (CIP) under 31 CFR § 1020.220. The CIP is the mandatory process by which every bank verifies who its customers are before opening an account — it is described in full at customer-identification. That data, together with your account type (personal or business, domestic or international), tells us what category of account this is and establishes what types of transactions are plausible for that category. This is the starting point for your profile.
Source 2: Your actual transaction history
As you use your account, the monitoring system observes the amounts, frequency, counterparties, corridors, and transaction types that characterize your account. This observed history becomes your profile. It is account-specific and it updates continuously — it reflects what you actually do, not what you said you would do. A declared intention at opening could change at any moment and would not be a reliable baseline anyway.
Why this matters for a source-of-funds request
When a transaction deviates materially from your established profile and no apparent lawful explanation is visible from the transaction data alone, the law requires us to examine "the available facts, including the background and possible purpose of the transaction" before deciding whether a SAR must be filed. Asking about the source of funds is how we gather those facts. The request is specific to that transaction — not a general audit of your account.
What moves an account between tiers
Two categories of trigger move an account from Tier 1 to Tier 2: the three mandatory SAR triggers under 31 CFR § 1020.320(a)(2), and sanctions-match events under 31 U.S.C. § 5318(l) and applicable OFAC regulations. No other factor — not a Member's position, nationality, occupation, or transaction volume alone — is a standalone trigger under federal law.
| Statutory trigger | Regulation | What it means in practice |
|---|---|---|
| Funds from illegal activity or designed to conceal them | 31 CFR § 1020.320(a)(2)(i) | The transaction involves funds that appear derived from illegal activities, or is structured to hide or disguise funds or assets from illegal activities — including concealing their ownership, nature, source, location, or control — as part of a plan to violate or evade any federal law or regulation. |
| Designed to evade BSA requirements | 31 CFR § 1020.320(a)(2)(ii) | The transaction appears designed to evade any requirement of 31 CFR Chapter X. This includes structuring — breaking up transactions specifically to avoid any BSA reporting requirement — which is independently prohibited under 31 CFR § 1010.314 regardless of the dollar amount or the type of reporting being evaded. |
| No apparent lawful purpose after examining available facts | 31 CFR § 1020.320(a)(2)(iii) | The transaction has no business or apparent lawful purpose, or is not the sort the customer would normally be expected to engage in, and we know of no reasonable explanation after examining the available facts. This is the trigger most likely to generate a source-of-funds request — gathering those facts is how we determine whether a reasonable explanation exists. |
| Sanctions match — account holder or counterparty | 31 U.S.C. § 5318(l); applicable OFAC regulations | The account holder or a transaction counterparty appears on a sanctions list maintained by OFAC or another authority to which we are subject. Because sanctions regimes are jurisdiction-specific, a match on one list does not necessarily mean every transaction is blocked — only transactions that fall within the scope of the applicable sanctions program are affected. See the note on jurisdiction-specific sanctions below. |
How jurisdiction-specific sanctions work
Sanctions are not uniform. OFAC administers dozens of distinct programs — each tied to a specific country, region, or category of designated persons — and each program defines precisely which transactions it prohibits. A person or entity may be designated under one program but not another, and a transaction may be prohibited under one program while being fully permissible under others.
Our system evaluates every transaction on its specific facts: the identity of the parties, the jurisdiction of the counterparty, the currency corridor, the nature of the transaction, and which sanctions programs apply to each element. If a Member appears on a sanctions list, that does not automatically restrict all of their transactions — it restricts only those transactions that fall within the scope of the program under which they are designated. The Terms of Service describe this transaction-by-transaction evaluation in Section 3 (Sanctions and restricted persons).
When a sanctions match is detected on a specific transaction, that transaction is blocked, rejected, or held for review as required by the applicable program. The account is elevated to Tier 2 for enhanced monitoring of subsequent transactions involving the same parties or corridors. OFAC blocking and rejection reports are filed as required. We may be legally prohibited from telling you the reason a specific transaction was blocked if doing so would reveal the existence of a regulatory filing.
Moving back down — how tier elevation ends
Being in Tier 2 or Tier 3 is not permanent. Federal law at 31 CFR § 1020.201(b)(1)(v)(B) requires us to maintain and update customer information "on a risk basis" — which means tier assignments must be reviewed and revised when the underlying basis for them changes. An account moves back to a lower tier when the condition that caused the elevation is resolved:
- SAR trigger resolved: the SAR evaluation is completed — either a SAR is filed and the pattern does not continue, or a reasonable explanation is confirmed and no SAR is required. Once resolved with no continuing pattern, monitoring returns to Tier 1.
- Sanctions match resolved: the specific transaction was blocked and filed as required, subsequent transactions involving the same parties or corridors show no further matches, and no ongoing pattern of sanctions-adjacent activity is detected. The account returns to Tier 1 monitoring for transactions that are not within the scope of the applicable sanctions program.
- Tier 3 pattern resolved: a sustained period — defined in our written BSA/AML program — passes without new triggers, and senior compliance review confirms the pattern is no longer active. The account steps down to Tier 2 first, then to Tier 1 if the Tier 2 evaluation also closes cleanly.
If your account has been elevated and you believe the underlying basis no longer exists, you can contact us through the in-app compliance channel (Account → Help → Compliance question). We will review the account and explain, to the extent permitted by law, what information we need to close the evaluation.
What we need from you
When a transfer triggers a compliance review, we will specify which payment category applies and what documentation is needed. All transfers are reviewed in the order they were submitted. Any transaction pending secondary review can be cancelled at any time from your end. All funds are held in a non-interest bearing escrow account for the duration of the review and returned immediately if the transaction is reversed.
For faster processing, we recommend using the tools available in ITAM to generate invoices, pay stubs, and structured digital contracts — these are accepted as documentation and help resolve reviews quickly. The in-app request will tell you exactly which category applies to your situation. You will never be asked to provide documentation for every category on this list.
Charitable contributions
Proof that the recipient organization is a registered entity whose primary purpose is philanthropy and social well-being (educational, religious, or other activities serving the public interest). Acceptable documents include:
- A current valid tax exemption certificate;
- A statement from a State taxing body, State Attorney General, or other appropriate State official certifying nonprofit status and that no net earnings accrue to private shareholders or individuals;
- A certified copy of the organization’s certificate of incorporation or similar document clearly establishing nonprofit status; or
- Any of the above for a State or national parent organization, together with a statement signed by the parent confirming the recipient is a local nonprofit affiliate.
Consulting, professional, legal, and advisory fees
Proof that the transfer is payment for consulting, professional, legal, or advisory services. Acceptable documents include an engagement letter, a representation contract, or an invoice.
Commission, royalty, trademark, patent, and copyright fees
Proof that the transfer is payment for commissions, royalties, trademarks, patents, or copyright fees. Acceptable documents include a licensing agreement, a copy of the patent or trademark (if the recipient is not named on the patent or trademark, also include proof of their ownership), an engagement letter, a representation contract, or an invoice.
Dividends and profits
Proof that the transfer is payment for dividends or profits. Acceptable documents include a contract attesting to the payment owed, proof of ownership or sale of securities by the recipient, or an invoice.
Education and tuition
Proof of enrolment in a school or education program offered by the recipient. If the recipient is an agent rather than the institution directly, also include proof of the relationship between the school and the agent.
Equity and commercial investments
A copy of a stock purchase agreement, executed term sheet, investment contract, or other document evidencing the equity or commercial investment. The amount of the transfer must match the payment terms identified in the documents you provide.
Friend or family (money remittance)
For direct family members: a copy of a birth certificate evidencing the relationship between parent and child, adoption papers where applicable, or a marriage licence or certificate. For non-direct family members or friends: proof that you know each other — for example, a photograph where both you and the recipient are clearly present.
Goods and services
An invoice matching the exact amount of the transaction. The documentation must be sufficient for our compliance team to confirm the legitimacy of the transaction and the accuracy of the amount.
Insurance payment
A copy of the insurance policy or contract, together with a payment statement or premium invoice as applicable.
Inter or intra group transfer (treasury)
Proof of the relationship between the two entities. A purely commercial relationship (buyer and seller) does not qualify for this category. Valid relationships include both companies being part of the same group, one company being owned by the other, or both companies being owned by the same shareholders. A substantial common majority shareholder may also be accepted in certain cases. Both the sender and the recipient must be named in the documentation provided.
Licensing fees
A copy of the licensing agreement between the sender and recipient, and/or an invoice as applicable.
Medical bills
A copy of an invoice for medical treatment, a hospital bill, or a payment statement from a clinic for medical services rendered.
Other
Documentation sufficient for our compliance team to confirm the legitimacy of the transaction and the accuracy of the amount. Because this category is a catch-all, the more specific the documentation, the faster the review.
Real estate lease or purchase
A copy of the lease agreement, purchase contract, bill of sale, or invoice as applicable.
Reimbursement
Proof of the original payment for which you are submitting the reimbursement. The documentation must include sufficient detail about the reason and purpose of the original payment. For example, if you are reimbursing an invoice previously paid in full or in part, include a copy of that invoice.
Salary and compensation
A copy of an employment agreement and/or other related bills, agreements, or contracts evidencing payments due as part of your professional engagement.
Settlement (dispute resolution)
A copy of the agreement or communication evidencing the settlement amount and the reason for the settlement.
Taxes and fees
A copy of a tax return, declaration, or statement of payment due to a tax authority or government entity. The payment being submitted must correspond to the documentation provided.
Transfer to own account (withdrawal)
A copy of a bank account statement in your name, or a bank letter confirming that the destination account is owned by you (the sender).
Transportation and travel costs
Proof of payment for transportation and travel-related costs, including lodging. Acceptable documents include a hotel reservation or bill, or proof of payment for airfare.
Utility bills
A copy of the utility bill for which you are submitting the payment.
How to respond to a request
When we need source-of-funds information, you will receive an in-app notification with a clear explanation of what we need and why. The request will specify:
- Which payment category applies (e.g., salary and compensation, goods and services, real estate lease or purchase) and what documentation is required for that category;
- The deadline for responding (typically 14 days for a standard request, 30 days for complex situations);
- The consequence of not responding — usually a temporary hold on outgoing transactions until we receive the information; and
- A link to this page and to the in-app upload tool.
If the documentation category does not match your situation, tap "My situation is different" in the in-app request. This routes you to a compliance agent who can discuss your circumstances and identify the right documentation.
If you need more time, tap "Request an extension". Extensions of up to 14 days are usually granted without requiring a reason.
What happens next
Once you submit documents, a compliance analyst reviews them. In most cases you will receive a decision within two business days. If we have a follow-up question, we will contact you through in-app messaging.
If the review is satisfactory:
- Any temporary hold on outgoing transactions is lifted immediately;
- Your account returns to normal operation; and
- The documented source-of-funds information is stored in your compliance file and you will not be asked again unless your risk profile changes materially.
If we are unable to verify the source of funds to our satisfaction, we will notify you and explain our next steps, which may include a further request for documentation, a limitation on specific transaction types, or — in cases where we cannot resolve the matter — closure of the account with return of your funds.
Common questions
No. A source-of-funds request is a routine compliance step triggered by objective risk criteria — not by suspicion of any specific wrongdoing. The overwhelming majority of Members who receive such requests provide their documentation and continue using their accounts without any issue. Every major bank in the world applies similar procedures.
Being at Tier 2 means a specific transaction on your account has triggered the mandatory SAR evaluation process under 31 CFR § 1020.320(a)(2). The tier is not a judgment about you — it is a description of where your account is in a statutory compliance process that the law requires us to complete.
Once the evaluation is resolved — either because a reasonable explanation is confirmed or because we complete any required SAR filing and the pattern does not continue — the account returns to Tier 1 monitoring. Most Tier 2 accounts resolve quickly once we receive the information we ask for.
We share your documents only as required or permitted by law. This includes responding to valid legal process (court orders, regulatory subpoenas), filing regulatory reports where required (such as Currency Transaction Reports to FinCEN), and — where we participate — voluntary information sharing with other financial institutions under Section 314(b) of the USA PATRIOT Act for AML/CFT purposes.
We do not sell your documents or share them for any commercial purpose. The full details are in our Privacy Notice.
No. Your job title, occupation, or public position is not a trigger under the three statutory SAR criteria (31 CFR § 1020.320(a)(2)). There is no definition of "politically exposed person" in U.S. federal law, and no provision of the Bank Secrecy Act or its implementing regulations requires a bank to screen for or apply special treatment to any person based solely on their political or government position.
A source-of-funds request from ITAM means a specific transaction on your account has triggered the SAR evaluation process. It is always about the transaction, not about who you are.
Tell us. Tap "My situation is different" in the in-app request to reach a compliance agent. We understand that not every situation fits a standard template — for example, if you are self-employed in a country that does not require formal tax returns, or if you received funds from a source that does not generate standard documentation.
Our goal is to understand the economic reality of your situation, not to collect a specific form. We will work with you to find documentation that satisfies our requirements.
U.S. federal law (31 CFR § 1020.220) requires banks to retain records related to customer identification and due diligence for five years after an account is closed. We retain source-of-funds documentation for the same period. After that, records are deleted in accordance with our data-retention schedule.
While your account is open, you can view the documents you have uploaded in the Account → Compliance section of the ITAM app.
Contact us
If you have questions about a source-of-funds request or about your risk tier, please reach us through the in-app messaging feature (Account → Help → Compliance question) or by email:
PayServices Bank — Compliance
950 W Bannock Street, Suite 1100
Boise, Idaho 83702-6140
United States
info@payservices.com
Related policies: Customer Identification Program · Source of Wealth · Beneficial Ownership Disclosure · Privacy Notice