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Payments & Banking Operational Explainer

When should a payment line of enquiry stop?

Stop when the material investigative question is answered proportionately or further work is unlikely to change the outcome - not merely because tracing is difficult or because a diagram looks complete.

Purpose defines sufficiency

The question may concern loss, recipient, controller, dissipation, benefit, recovery or wider links. Once it is proved, disproved or cannot realistically be resolved, additional tracing may add cost without evidential value. Missing records or an opaque service can create a justified limit, but specialist support and recovery prospects should be considered.

Record the stopping decision

Document traced events, providers contacted, unresolved issues, seriousness, value, vulnerability, intelligence and proportionality. Do not call the last visible address the final beneficiary without evidence.

Identify a trigger that could reopen the line where appropriate.

The point to remember

End tracing when it has answered the operational question or cannot proportionately do so, and make that reasoning transparent.

Reference: PAY-230Payments & Banking