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Financing the unknown

Jeremy was using the services of a money transfer company to transfer thousands of dollars to an individual, whom he had never met, in Russia. The transfer company spoke to Jeremy on a number of occasions and requested proof of income or the source of the funds he was using to transfer. This was in order to satisfy themselves that the funds were originating from a legitimate source and to fulfill their anti-money laundering requirements. Jeremy was unable to provide the information, nor was he able to provide evidence of the relationship with the recipient of the money. The money transfer company suspected that Jeremy was a victim of a scam.

As a result of not providing any documentation, the money transfer company blocked Jeremy’s account. They believed that Jeremy may be a genuine victim of fraud, and it was acting in his best interests. Jeremy disagreed with the transfer company’s decision to refuse to provide him with its service and felt that the transfer company should reactivate his account. The transfer company declined to do so and Jeremy complained to FSCL.

FSCL declines jurisdiction

After careful consideration, we decided not to further investigate as the complaint related to the transfer company’s practice or policy.

Under our terms of reference, we may refuse to consider, or continue to consider, a complaint, if we consider the participant (the transfer company) was acting in accordance with its standard practice or policy, and that practice or policy does not breach any obligation the participant may owe to its client. The complaint related to the transfer company’s practice or policy. The transfer company’s terms and conditions allowed it to terminate a user’s access and registration to any part, or all of, the transfer company’s site and related services, with or without cause.

We wrote to Jeremy explaining our finding, and gave him the opportunity to respond.

Jeremy did not reply, and we closed the file.


FSCL will use its discretion to exclude a complaint where it considers the action taken by the scheme participant is clearly relates to the participant’s practice or policy.