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Payments & Banking Operational Explainer

How should bank-account attribution be worded?

Distinguish the registered holder, practical controller, transaction user and beneficiary. Use the term matching the evidence rather than treating an account “belonging to” someone as proof of every payment.

Registration establishes a customer relationship

Opening, identity, contact and card records can show an account registered to a person. Transactions, endpoints and beneficiaries establish account activity. Shared, compromised or remotely controlled access can separate both from the user at a particular time.

Calibrate the personal statement

Say that an account was registered to or associated with a person and that a transaction was recorded against it. Add login, authentication, endpoint or communication evidence where it supports operation.

If the user is unresolved, say so. Control also differs from beneficial ownership: a person can move value for another or receive it without retaining it.

The point to remember

Attribute individual bank transactions only where evidence goes beyond the registered account name to identify the relevant user.

Reference: PAY-223Payments & Banking