Third-Party Bank Accounts in International Trade: When Additional Due Diligence Is Required

Distinguish a disclosed structure from an unexpected change.

An agreed collection arrangement documented at the start should be reviewed on its merits. A new beneficiary introduced immediately before release requires a fresh check of the changed instruction as well as the underlying arrangement. Do not merge the two into a generic “third-party account risk” score.

Identify the entity being paid.

Record the beneficiary’s full legal name, registration jurisdiction, identifier and stated role. Distinguish that entity from its bank and any trading brand. Compare the current agreement, invoice and instruction against the role map. For a Brazilian recipient, obtain the corporate record from the official CNPJ route rather than relying on a supplied extract.

If a group relationship is offered as the explanation, trace it to appropriate records. A shared director, domain or office is an indicator, not conclusive ownership evidence. An independently established group link can support identity context while leaving the right to collect the seller’s receivable unanswered.

Ask for the transaction-specific basis.

Request the collection, assignment, agency or other instrument relied on. Identify the parties, signatures, date, underlying obligation and any conditions. Ask counsel to assess enforceability and whether payment to the recipient would discharge the buyer’s intended obligation. The investigator should supply the facts, not declare a structure lawful because its label sounds familiar.

Check that the person issuing the instruction has authority for this act. Authority to negotiate a sale is not automatically authority to redirect proceeds. If another intermediary supplies the explanation, trace it back to the relevant principal through a permitted, independently established route. Repetition within the same chain is not independent confirmation.

Verify a change without reusing its contact channel.

Preserve the change request and pause its automatic processing under your internal controls. Compare the sender, timing and wording with the established correspondence, but do not rely on a familiar-looking email account as authentication. Use a previously established contact or obtain one independently; do not use only the phone number or reply address supplied in the request itself.

Ask the authorized principal to confirm the transaction, old and new instructions and reason for change through the approved secure process. Record the responder and how the channel was established. Send bank-authentication questions to the bank. Have a second authorized person review the change if your process requires dual control, and keep the evidence with the approval.

Keep factual research and bank verification distinct.

Public corporate records do not establish that an account belongs to a particular entity, that funds are available or that a bank accepted a payment arrangement. A bank-branded letter or purported message needs appropriate authentication through authorized professionals. An investigator cannot fill that gap by examining fonts, metadata or signatures visually.

Where an instrument is involved, have the bank assess the beneficiary and the mechanics separately from the commercial findings. ICC’s trade-finance resources provide institutional context; they are not an endorsement of a particular arrangement. Screen the correctly identified parties under the applicable frameworks without treating a no-match result as approval of the payment.

Escalate precisely — especially if money has already moved.

Use a finding such as “The proposed recipient exists and its affiliation is supported; the authority to collect this receivable has not been independently confirmed.” Identify the missing instrument or response and the owner responsible for resolving it. A recipient that matches the seller is not proof that the rest of the transaction is sound either.

If a change appears unauthorized and a transfer has already been sent, promptly contact the sending bank through a trusted channel and follow its fraud-response instructions. Preserve the correspondence and notify the appropriate internal team. Further corporate research is not a substitute for timely bank notification, and no recovery outcome can be assumed.