Holds

Wire holds

A wire transaction on-hold status is a measure Cross River takes to protect our customers. Holds are a reflection of internal policies and regulatory requirements designed to mitigate risks like fraud, financial instability, or compliance violations. The Wire Holds area in COS Explorer displays information on the holds imposed on the wire, including the status of the hold and the type of the hold.

In some cases, system validations may trigger a hold for a variety of reasons explained below.

Type	Reason	Applies to	Clearing method
Beneficiary Account	The beneficiary account number in the payment did not match an account in COS	Inbound	Automated, Manual
Beneficiary Title	The beneficiary name in the payment did not match the beneficiary account title	Inbound	Automated, Manual
Catchy Scan	Some of the payment details potentially matched information within our fraud prevention database	Inbound, Outbound	Automated, Manual
Collected Funds	The core was unable to successfully collect funds for the payment from the originator’s account	Outbound	Automated
Duplicate Suspect	Some of the payment details matched a payment that has been processed within the same business day	Inbound, Outbound	Automated, Manual
Inbound International	Some of the payment details indicate that the payment is an international transaction	Inbound	Automated, Manual
Internal Review	The payment was originated by an internal user via the COS Explorer portal	Outbound	Manual
Manual	Miscellaneous hold placed on a wire	Inbound, Outbound	Manual
OFAC Scan	Some of the payment details potentially matched information within the OFAC database	Inbound, Outbound	Automated, Manual
Outbound International	Some of the payment details indicate that the payment is an international transaction	Outbound	Automated
Authorization	The amount of the wire requires one or more approvals. One or more partner users must access COS Explorer to clear the hold.	Outbound	Manual
Phone Confirmation	The payment was originated by an external user (partner) via the COS portal and must be processed using the Bank’s callback verification procedure	Outbound	Automated, Manual
Travel Rule	The payment is missing some information that is required by the FinCen Travel Rule - see below for more information	Outbound	Automated

Wires must achieve a pending status to be eligible for distribution.

This happens when either:

The validation process did not trigger any holds

All triggered holds were manually cleared by a user

Travel Rule

The Bank Secrecy Act Travel Rule (31 CFR 1010.410(f)) requires information identifying the sender of a wire to travel with the payment, so that the receiving institution and any bank in between can tell who sent the funds. It applies to transfers of $3,000 or more.

Always supply:

Originator name

Originator address - street, city and country at a minimum

Originator account number, or another identifier if no account was used

Wires missing any of these may be held for compliance review. We cannot supply the missing details on your behalf and the payment is returned to you for correction.

To avoid holds, send complete originator details on every wire, or configure a default originator on the account and let us populate it.